Summary

Hansraj v. State of Chhattisgarh (2025 INSC 178)

Headnotes:

• Criminal Law – Circumstantial Evidence: Conviction based solely on circumstantial evidence requires an unbroken chain leading to guilt.

• Last Seen Theory: Mere presence of an accused near the scene of the crime is insufficient without corroborating evidence.

• Recovery of Weapon: Delay in recovery and lack of forensic corroboration weaken prosecution claims.

Detailed Summary:

Hansraj was convicted of murdering his employer based on circumstantial evidence. The prosecution claimed he was last seen with the victim and that a bloodstained farsi (axe) was recovered on his disclosure. However, the Supreme Court found inconsistencies in witness statements and noted the lack of forensic evidence linking the weapon to the crime. The Court held that the chain of circumstances was incomplete and acquitted Hansraj, reiterating that circumstantial evidence must lead to only one possible conclusion—guilt. 

• Facts: The accused was convicted for the murder of his employer. The prosecution’s case relied on circumstantial evidence, including last-seen theory and weapon recovery.

• Key Arguments:

  • Prosecution: The accused was last seen with the deceased and fled after the incident. A bloodstained weapon was recovered at his instance.

  • Defense: No direct evidence; discrepancies in witness testimonies; forensic evidence did not conclusively link the weapon.

• Supreme Court’s Decision:

  • Failure of Last Seen Theory: The accused’s presence was not corroborated independently.

  • Doubtful Recovery: The weapon was recovered after 25 days, and no forensic link was established.

  • Chain of Circumstances Broken: The evidence did not exclude every hypothesis of innocence.

• Final Holding: Acquitted the accused due to lack of conclusive evidence.