CASE: GAUTAM SATNAMI v. STATE OF CHHATTISGARH
PETITION NUMBER: CRIMINAL APPEAL NO. 1782 OF 2026 (ARISING OUT OF S.L.P. (CRIMINAL) NO.11080 OF 2022)
CITATION: 2026 INSC 325
DATE OF JUDGEMENT: 07.04.2026
HON’BLE JUDGE/ CORUM: HON’BLE JUSTICE PRASHANT KUMAR MISHRA AND HON’BLE JUSTICE VIPUL M. PANCHOLI
INTRODUCTION
Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi, on April 7, 2026, stated that. ‘the evidence on record may raise suspicion, but, suspicion, however strong, cannot take the place of proof.’ while, setting aside the judgment of the High Court of Chhattisgarh, and acquitted the appellant (the accused No. 1) for charges under Section 302 of Indian Penal Code, 1860 (IPC) on the grounds that he too deserved the benefit of doubt similar to the accused No. 2 who had been since acquitted.
FACTUAL MATRIX
On the day of the alleged incident, the appellant and accused No. 2 were found quarrelling with the deceased at his house. The appellant had a liquor bottle in his hand and was abusing the deceased, saying that because of him, he had gone to jail, and one day he would kill him. The appellant and the deceased had ongoing animosity in their friendship due to a prior incident, which led to the appellant going to jail.
As per the prosecution, the accused persons went to the deceased’s house at night armed with axes and inflicted multiple incised injuries on him, resulting in instantaneous death on account of shock due to excessive haemorrhage. Thereafter, the accused persons fled the scene. The deceased’s body was discovered the next day.
Police officials reached the spot, prepared the inquest panchnama, and sent it for post-mortem. The Police recorded that they collected the blood-stained hairs and soil, liquor bottles, and the driver’s license of the appellant from the spot. Medical opinion was that death occurred due to shock caused by excessive haemorrhage and had taken place approximately between 4:30 p.m. and 10:30 p.m. on the previous day. Later, the Police took the accused persons into custody. Allegedly, they gave confessional statements based on which they were arrested.
ISSUES INVOLVED
The Supreme Court primarily considered:
- Whether the circumstantial evidence presented by the prosecution formed a complete and unbroken chain sufficient to prove the appellant’s guilt beyond a reasonable doubt under Section 302 IPC?
- Whether the Supreme Court should exercise its discretionary power under Article 136 to interfere with concurrent findings of guilt to prevent a manifest miscarriage of justice?
SUBMISSIONS BY THE PARTIES
Learned Senior Counsel Mr A. Sirajudeen, on behalf of the appellant, contended that the prosecution has failed to present the true origin and genesis of the incident and that the material contradictions and omissions elicited during cross- examination, which were favourable to the appellant, were either ignored or improperly appreciated. He further contended that most prosecution witnesses did not support the prosecution’s case vis-à-vis its material particulars. It was also urged that while accused No. 2 was acquitted on the same circumstantial evidence, the appellant was convicted without any sustainable distinguishing circumstance. He further argued that the prosecution did not prove the charge under Section 302 of the IPC beyond a reasonable doubt, and the conviction is totally unsustainable in law.
Learned Deputy Advocate General for the State of Chhattisgarh, Mr Praneet Pranav, on behalf of the prosecution, submitted that the instant case is a proven case of murder. He contended that both the Trial Court and the High Court correctly appreciated the evidence, and there is no perversity warranting interference under Article 136 of the Constitution. The prosecution’s case established several incriminating factors:
- Prior enmity between the appellant and the deceased.
- A threat issued by the appellant on the evening preceding the incident.
- The presence of the appellant near the deceased’s house on the night of the incident, carrying an axe.
- Recovery of a blood-stained axe and clothes pursuant to disclosure under Section 27 of the Evidence Act, and recovery of the appellant’s driving licence from the spot.
- Detection of human blood and hair on seized articles as per the FSL report.
It was further submitted that the appellant failed to offer any plausible explanation under Section 313 of the Cr.PC regarding these circumstances, which form a complete and unbroken chain pointing to his guilt.
JUDGEMENT ANALYSIS
The Hon’ble Bench acknowledged the distinction between criminal appeals under Article 134, where the Court sits as a regular court of appeal, and discretionary jurisdiction under Article 136. Under Article 136, the Court ordinarily limits itself to correcting manifest illegality or grave miscarriages of justice. However, these restrictions are not absolute; the Court maintains a final Constitutional responsibility to ensure justice is done, even in cases of concurrent findings of guilt.
In scrutinising the prosecution’s case, the Court clarified that a ‘related’ witness is not necessarily ‘interested’, nor vice versa. Based on the record, it was plausible that a key witness and his associates harboured longstanding hostility toward the appellant. Because the witness may have had a direct or indirect interest in seeing the appellant punished, his testimony could not sustain a conviction without independent corroboration.
The strongest circumstance against the appellant, the ‘last-seen’ evidence, was found lacking. The conditions for reliable visual identification at night were doubtful, and medical evidence failed to fix the time of death with enough precision to correlate the appellant’s presence with the crime. At best, the deposition placed the appellant in the vicinity, which lacks the clinching value required to sustain a conviction.
Regarding incriminating circumstances, the Court noted that under Section 25 of the Evidence Act, confessions to police are inadmissible. Since the Trial Court admitted the case, which relied entirely on circumstantial evidence, a careful re-examination was necessary where the chain of evidence was exposed to doubt. The Court emphasised that every circumstance must be fully established and consistent only with the hypothesis of guilt. In this case, the prosecution failed to establish a chain of evidence so complete as to leave no reasonable ground for the conclusion of innocence.
CONCLUSION
The Supreme Court set aside the appellant’s conviction, emphasising that the prosecution’s case fails at the threshold itself, as each circumstance from which guilt is to be inferred is not firmly and fully established. The circumstances of the case invoked the principle of parity, and the Court ruled that since the evidence against the appellant was substantially similar to that of the acquitted co-accused, he was entitled to the benefit of doubt.
