SUPREME COURT RULLING ON ACQUITTAL IN A MURDER CASE

by Nancy Sharma | Feb 10, 2025

ASPECTS	DETAILS
Case Title	Raja Khan vs. State of Chhattisgarh (2025 INSC 167)
Introduction	The appeal challenges the Chhattisgarh High Court’s judgment upholding the conviction and sentence of Raja Khan under Sections 302 and 201 IPC. The Supreme Court examines the evidence and procedural aspects of the case.
Factual Background	The deceased, Neeraj Yadav, went missing on 29th November 2013. His dead body was found floating in a quarry pond on 2nd December 2013. The prosecution alleged that the appellant murdered the deceased over a financial dispute and attempted to dispose of the body. The trial court convicted Raja Khan, sentencing him to life imprisonment under Section 302 IPC and five years under Section 201 IPC. The High Court upheld the conviction.
Legal Issues	Whether the prosecution proved an unbroken chain of circumstantial evidence linking the accused to the crime. Admissibility and reliability of the accused’s disclosure statement under Section 27 of the Evidence Act. Validity of the ‘last seen’ theory in the absence of corroboration. Inconsistencies in the recovery of incriminating materials and forensic findings.
Applicable Law	Indian Penal Code, 1860 – Sections 302 (Murder), 201 (Causing Disappearance of Evidence). Indian Evidence Act, 1872 – Section 27 (Admissibility of Discovery Statements). Code of Criminal Procedure, 1973 – Section 313 (Examination of Accused).
Analysis	The Supreme Court scrutinized the circumstantial evidence and held that the prosecution failed to establish an unbroken chain linking the accused to the crime. Witness testimonies regarding the last-seen circumstance were inconsistent. The court also found grave procedural lapses in the recovery process, questioning the credibility of the police investigation. The forensic evidence was not conclusively linked to the accused. The seizure memos prepared at the police station, rather than at the recovery site, cast further doubt on the prosecution’s version.
Conclusion	The Supreme Court held that the prosecution failed to prove the accused’s guilt beyond a reasonable doubt. The appellant was given the benefit of the doubt, and his conviction was set aside. The court ordered his immediate release.
Current Scenario	The judgment sets a precedent on the importance of an unbroken chain of circumstantial evidence and the necessity of adhering to procedural safeguards in criminal trials. The case highlights judicial scrutiny of police investigations and evidentiary requirements in criminal appeals.

CASE SUMMARY – The Supreme Court has overturned the conviction of Raja Khan for murder and disposal of evidence under Sections 302 and 201 IPC. The case relied on circumstantial evidence, including a ‘last-seen’ theory and alleged recovery of murder weapons. The court found inconsistencies in witness testimonies, procedural lapses in evidence recovery, and insufficient forensic linkage. Holding that the prosecution failed to prove guilt beyond reasonable doubt, the court set aside the conviction and ordered the appellant’s immediate release, reinforcing the principle of strict evidentiary standards in criminal trials.

“The Supreme Court held that the prosecution failed to prove the accused’s guilt beyond a reasonable doubt. The appellant was given the benefit of the doubt, and his conviction was set aside. The court ordered his immediate release.”

SOURCE – SUPREME COURT OF INDIA

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Written By Nancy Sharma

I am Nancy Mahavir Sharma, a passionate legal writer and a judicial service aspirant who is interested in legal researching and writing. I have completed Latin Legum Magister degree. I have been writing from past few years and I am excited to share my legal thoughts and opinions here. I believe that everyone has the potential to make a difference.