Circumstantial evidence requires a complete chain; withholding best evidence and medical doubt led to benefit of doubt.

In a conviction based solely on circumstantial evidence, each incriminating fact must be firmly proved and form an unbroken chain consistent only with guilt. Withholding crucial CCTV footage, treated as the best evidence on the accused's presence, justified an adverse inference and left a serious gap in the prosecution case. The alleged motive was weakened by material improvements, the presence evidence was unreliable, and the medical evidence did not conclusively establish strangulation because key symptoms were absent. On this record, the prosecution failed to exclude reasonable doubt, so the conviction was held unsafe and the accused received the benefit of doubt.

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Issues: Whether the conviction based on circumstantial evidence could be sustained in the absence of a complete chain of circumstances, having regard to the non-production of CCTV footage and other best evidence, the alleged plea of alibi, the motive evidence, and the medical evidence regarding cause of death.

Analysis: The prosecution case rested entirely on circumstantial evidence, so each incriminating circumstance had to be firmly proved and collectively form an unbroken chain inconsistent with innocence. The Court found that the prosecution withheld crucial CCTV footage, which was the best evidence to show whether the accused remained in the hotel room or had gone out, and this omission justified an adverse inference against the prosecution. The Court also noted that the alleged motive was introduced through material improvements, the hotel-room presence evidence was not fully reliable, and the medical evidence did not conclusively establish strangulation because the usual symptoms of strangulation were largely absent and the post-mortem findings raised doubts. In these circumstances, the prosecution failed to dispel reasonable doubt.

Conclusion: The conviction could not be sustained; the accused were entitled to the benefit of doubt and the finding of guilt was set aside in favour of the appellants.

Final Conclusion: The prosecution evidence did not complete the required chain of circumstances, and the omission to produce the crucial electronic evidence, coupled with doubt on motive and cause of death, made the conviction unsafe.

Ratio Decidendi: In a case based solely on circumstantial evidence, conviction cannot stand unless all material links are proved beyond reasonable doubt and any withholding of the best available evidence, especially when it creates a serious gap in the chain of circumstances, entitles the accused to benefit of doubt.

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