Supreme Court Restores Acquittal in Meghalaya Murder Case, Citing Lack of Evidence Supreme Court overturns High Court's conviction, citing failure of prosecution to establish guilt beyond reasonable doubt in Bernard Lyngdoh Phawa case.
In a significant judgment, the Supreme Court of India has restored the acquittal of Bernard Lyngdoh Phawa, previously convicted of murder by the High Court of Meghalaya. The apex court emphasized the prosecution's failure to establish a complete chain of incriminating circumstances and the unreliable nature of the confessions obtained from the accused.
The case originated from a missing person complaint that led to the arrest of Bernard Lyngdoh Phawa and another accused. The High Court had reversed the trial court's acquittal, convicting Phawa for murder under Sections 302 and 201 of the Indian Penal Code, 1860. However, the Supreme Court found that the prosecution's reliance on circumstantial evidence, including the last seen theory and confessions, was insufficient to uphold the conviction.
The Supreme Court highlighted that the prosecution did not establish a complete chain of circumstances excluding all other hypotheses of innocence. The court found the confessions of the accused to be unreliable due to inconsistencies and lack of corroboration. Additionally, the Supreme Court noted procedural lapses, such as the failure to inform the accused of their right to legal aid during the recording of confessions, which further undermined the credibility of the confessions.
The Supreme Court also addressed the recovery of a rope allegedly used for strangulation, noting the absence of forensic evidence linking it to the crime scene. The court observed that such recoveries could not be relied upon as incriminating evidence without conclusive links to the crime.
In its judgment, the Supreme Court reiterated the principles governing circumstantial evidence as laid out in previous cases, emphasizing the need for a complete and unbroken chain of evidence to convict an accused based on circumstantial evidence alone.
The judgment underscores the importance of adhering to legal principles and procedural safeguards in criminal trials, particularly in cases relying heavily on circumstantial evidence. The Supreme Court's decision reaffirms the trial court's initial acquittal, directing the immediate release of the accused if they are not involved in any other cases.
Bottom Line:
In cases of circumstantial evidence, the prosecution must establish a complete chain of incriminating circumstances, excluding all possible hypotheses of innocence. Confessions must be voluntary, corroborated, and directly acknowledge guilt to serve as the basis for conviction.
Statutory provision(s): Indian Penal Code, 1860 - Sections 302, 201; Evidence Act, 1872 - Section 27; Criminal Procedure Code, 1973 - Section 164
Bernard Lyngdoh Phawa v. State of Meghalaya, (SC) : Law Finder Doc Id # 2844138
