The Andhra Pradesh High Court acquitted four accused in a murder case after finding that although the corpus delicti and the identity of the deceased were established, the prosecution failed to prove the chain of circumstances connecting the accused to the crime beyond reasonable doubt. The Division Bench comprising Justice K. Suresh Reddy and Justice A. Hari Haranadha Sarma allowed the criminal appeal and set aside the conviction and sentences imposed by the trial court.
The court observed that the identity of the deceased and the homicidal nature of her death were clearly established. It noted that P.W.1, the daughter of the deceased, identified several personal belongings of her mother at the time of exhumation, including a saree, blouse, petticoat, slippers, a gold-coloured dollar bearing the face of Lord Venkateswara, a cut piece of gold-coloured chain, and a pair of sky blue-coloured chappals. These identifications were made in the presence of the Mandal Revenue Officer and other witnesses. The court concurred with the trial judge’s findings on these points, stating that the identity of the deceased and the homicidal nature of her death were clear.
The post-mortem evidence further confirmed that the cause of death was a severe head injury, supporting the conclusion that the death was homicidal. The court acknowledged that corpus delicti—proof that a person died due to a criminal act—had been established through the exhumation and identification process.
However, the Bench emphasized that establishing the fact of death and identity of the deceased was insufficient to prove the guilt of the accused. It held that the prosecution had failed to establish the remaining links in the chain of circumstances necessary to connect the accused to the murder beyond reasonable doubt.
The court specified the missing links in the circumstantial evidence: (1) proof of access of the accused to the deceased, (2) evidence that the accused were last seen with the deceased, (3) the confession of the accused leading to the discovery of the corpse or the deceased’s gold jewellery, (4) the role or possibility of the accused in the homicidal death, and (5) the motive for the accused to eliminate the deceased. The Bench held that none of these links were proved beyond reasonable doubt.
Regarding the alleged extra-judicial confessions, the court found them unreliable. It held that the confession attributed to A1 to A3, made before witness P.W.5, could not be relied upon to prove their guilt or to connect them with the recovery of the body and jewellery. Similarly, the alleged confession of A4, made in the presence of police, was also deemed unreliable and inadmissible as evidence of guilt.
The court noted that the prosecution’s case rested primarily on these extra-judicial confessions, which purportedly led to the exhumation of the body and recovery of ornaments. However, it found that the confessions suffered from numerous doubts and could not serve as the sole basis for conviction. The Bench stated that from the evidence of prosecution witnesses, it was clear that the confession of the accused was the only source for the recovery of the corpus and material objects, and this reliance was problematic due to the inherent weaknesses in the confession evidence.
The court concluded that the accused were entitled to the benefit of doubt due to the failure of the prosecution to establish the complete chain of circumstances. Accordingly, it allowed the criminal appeal, set aside the conviction and sentences passed by the trial court, and ordered the acquittal of all four accused.