SCOI Acquits Man Convicted of Murder: Circumstantial Evidence Found Inadequate

In Thammineni Bhaskar v. State of Andhra Pradesh (2025 INSC 1124), the Supreme Court reaffirmed a cornerstone principle of criminal law that conviction cannot rest on shaky or incomplete circumstantial evidence.

What's The Matter?

The case arose out of the alleged abduction and murder of an auto driver, Bhoominadhan, in March 2016. Bhaskar, along with others, was accused of forcibly dragging the deceased into an auto rickshaw, assaulting him, and later killing him.

The trial court convicted him under Sections 302 (murder), 364 (kidnapping), and 201 (causing disappearance of evidence), sentencing him to life imprisonment. The Andhra Pradesh High Court upheld the conviction.

What Court Said?

When the matter reached the Supreme Court, the Bench scrutinised the evidentiary foundation of the conviction. The prosecution’s case hinged almost entirely on two supposed eyewitnesses PW-5 and PW-6. In their initial police statements, they had claimed to see the deceased being dragged and assaulted.

Yet, in court, they turned hostile, admitting only to having noticed a commotion near a banyan tree without being able to identify who was involved. This retraction stripped the case of its direct evidence.

Despite this, both the trial court and the High Court leaned on the hostile witnesses’ prior statements and on an alleged motive stemming from previous enmity.

The Supreme Court, however, underscored that motive is at best a supporting circumstance, never a substitute for proof.

Citing the celebrated Sharad Birdhichand Sarda v. State of Maharashtra (1984), the Court reiterated the “five golden principles” governing circumstantial evidence:

(1) the circumstances must be fully established,

(2) they must be consistent only with the guilt of the accused,

(3) they must exclude every other hypothesis,

(4) they must form a complete chain, and

(5) the chain must point conclusively to the accused.

Here, the Court found multiple gaps.

The alleged eyewitness testimony collapsed; there was no credible last-seen evidence; the forensic and medical reports did not link the accused to the crime; and motive alone could not bridge these gaps.

In fact, the prosecution failed to demonstrate that the appellant was even present with the deceased at the relevant time.

The so-called chain of circumstances was riddled with missing links, falling far short of the standard of “beyond reasonable doubt.”

The Court was also critical of how lower courts treated hostile witnesses. It reminded that once witnesses retract their statements, their earlier police depositions cannot by themselves be the basis of conviction unless corroborated by other credible evidence.

The High Court’s attempt to read guilt into mere suspicion and past enmity was, therefore, legally unsustainable.

Allowing the appeal, the Supreme Court acquitted Bhaskar, setting aside both the trial and appellate judgments, and directed his immediate release.

This ruling underscores a timeless caution in criminal jurisprudence: the liberty of an individual cannot be sacrificed at the altar of conjecture or incomplete proof.

Circumstantial evidence can indeed convict but only if it forms an unbroken chain leading solely to the guilt of the accused.

Where that chain breaks, even once, the benefit of doubt must necessarily flow to the accused.

The judgment is thus both a rebuke to hasty reliance on suspicion and a reaffirmation of the principle that “suspicion, however strong, cannot take the place of proof.” 

It preserves the balance between society’s interest in punishing crime and the individual’s right not to be condemned on inadequate evidence.