LexGAUTAM SATNAMI versus STATE OF CHHATTISGARH
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[2026] 4 S.C.R. 417 : 2026 INSC 325 Gautam Satnami v. State of Chhattisgarh (Criminal Appeal No. 1782 of 2026) 07 April 2026 [Prashant Kumar Mishra* and Vipul M. Pancholi, JJ.] Issue for Consideration Whether in the facts and circumstances of the case, the appellant is entitled to the benefit of doubt and ought to be acquitted of the charge u/s.302 IPC. Headnotes† Circumstantial evidence – Suspicion howsoever strong, cannot take the place of proof – Appellant was convicted u/s.302, IPC based on inter alia the ‘last-seen’ testimony of PW-4; recovery of a blood-stained axe and clothes pursuant to disclosure u/s.27; and recovery of the driving licence of the appellant from the spot – Interference with: Held: The ‘last-seen’ testimony of PW-4 does not inspire confidence – The major distinction between the case of the present appellant and that of accused No. 2 (who was acquitted) is the ‘last-seen’ testimony of PW-4 – If that circumstance is excluded from consideration, the position of the present appellant is similar enough to that of accused No. 2 and it would be unsafe to sustain the conviction of the former, at least preponderantly on the basis of this circumstance – Witnesses have either turned hostile or not corroborated the case of prosecution on any material particulars in relation to the recoveries beyond just admitting their signatures – FSL report confirmed that it was human blood that was present on the axes and clothes; however, the blood group of either the deceased or of the blood present on the weapons or clothes was not determined; though it was observed the hair present on the axes was similar in morphological and microscopical characteristics to the hair recovered from the spot, no conclusive opinion was given if it belonged to the deceased; and there was no definitive link * Author 418 [2026] 4 S.C.R. Supreme Court Reports made between the recovered axes and the deceased’s injuries – The recovery circumstance remains legally tenuous – Remaining circumstances are also weak and inconclusive – As regards motive, it is a supporting factor which strengthens an otherwise complete chain of evidence but, it cannot replace such a chain where other circumstances are missing or weak – Prosecution’s case fails at the threshold itself, as each circumstance from which guilt is to be inferred is not firmly and fully established – Evidence on record may raise suspicion, but, suspicion, however strong, cannot take the place of proof – Appellant, like accused No.2 deserves the benefit of doubt – Judgment passed by the High Court affirming the judgment of the Sessions Judge, is set aside insofar as it relates to the appellant – Appellant acquitted – Evidence Act, 1872 – ss.25, 27. [Paras 22, 24-26, 30, 31 ] Constitution of India – Arts.134, 136 – Distinction between criminal appeals as a matter of right u/Art.134 and the broader, discretionary jurisdiction exercised by this Court u/Art.136: Held: u/Art.134, this Court sits as a regular court of appeal, but u/Art.136, ordinarily limits itself to correcting manifest illegality and/or grave miscarriage of justice – This is particularly apposite in a case like the present Appeal, where the Courts below have returned concurrent findings of guilt – However, restrictions are not absolute – In fact, both provisions underline that this Court has the final, Constitutional responsibility to ensure that justice is done, and hence, the nature and scope of Court’s powers u/Art.136 are not curtailed where the interests of justice so require. [Paras 12, 13] Evidence – ‘related’ witness; ‘interested’ witness – Testimony of interested witness without corroboration cannot sustain conviction: Held: A ‘related’ witness is not necessarily an ‘interested’ witness, and an ‘interested’ witness need not be a ‘related’ one – Based on the evidence on record, it is plausible that a witness such as PW-4 had the requisite direct or indirect interest in seeing the appellant punished – His examination-in-chief and cross-examination disclose circumstances suggesting that he himself, or at least his ‘group’ or the persons closely associated with him, harboured longstanding hostility towards the appellant – Therefore, the finding of the Trial Court that it was “not established that the witness had any animosity with the accused”, or of the High Court that there is “no [2026] 4 S.C.R. 419 Gautam Satnami v. State of Chhattisgarh reason to disbe
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