Circumstantial evidence in murder cases must form a complete chain; doubtful medical proof and missing motive defeated conviction.

A conviction under Section 302 IPC based on circumstantial evidence was held unsafe where the medical opinion was doubtful, usual indicia of asphyxial death were absent, and the alleged motive from cruelty and dowry demand had not been proved. The deceased being with the accused at the relevant time was insufficient to complete the chain of circumstances without proof of violence or other conclusive links. The prosecution retained the primary burden throughout, and where two views were possible the benefit of doubt applied. The conviction was set aside and the accused was acquitted.

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Issues: Whether the conviction under Section 302 of the Indian Penal Code, 1860 was sustainable on the basis of circumstantial evidence, medical opinion, and the surrounding circumstances.

Analysis: The prosecution case rested on an inference of homicidal smothering, but the medical evidence was not free from doubt and several usual indicia of asphyxial death were absent. The courts below had disbelieved the evidence relating to cruelty and dowry demand, so the motive alleged by the prosecution did not survive. The fact that the deceased and the appellant were together at the relevant time could not, by itself, complete the chain of circumstances in the absence of proof of violence or other conclusive links. Failure to establish the defence version did not relieve the prosecution of its primary burden, and the benefit of doubt remained available where two views were possible. The conviction founded on suspicion, rather than a complete and consistent chain of circumstances, was therefore unsafe.

Conclusion: The conviction under Section 302 of the Indian Penal Code, 1860 was not sustainable and was set aside; the appellant was entitled to acquittal.

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