Circumstantial evidence upheld rape and murder conviction, but medical age assessment secured juvenile benefit and set aside sentence.

Circumstantial evidence can sustain conviction for rape and murder where the circumstances form a complete chain pointing unerringly to the accused and excluding any reasonable alternative hypothesis; on that basis, the conviction under the Penal Code was upheld. Separately, where no documentary proof of age is available, a duly constituted medical board's radiological and clinical assessment may be accepted under the Juvenile Justice Rules to determine minority; applying that approach, the appellant was treated as a juvenile on the date of occurrence and the sentence was set aside, while the conviction remained intact.

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Issues: (i) Whether the prosecution had established the appellant's guilt for rape and murder by a complete chain of circumstantial evidence. (ii) Whether the appellant was a juvenile on the date of occurrence and entitled to the benefit of the juvenile justice regime, warranting setting aside of the sentence.

Issue (i): Whether the prosecution had established the appellant's guilt for rape and murder by a complete chain of circumstantial evidence.

Analysis: The prosecution case rested entirely on circumstantial evidence. The appellant was shown to have been present at the night prayer meet, the deceased child was last seen there before being found dead with injuries indicative of rape and homicidal violence, blood-stained clothes of the appellant were recovered pursuant to disclosure, the blood group on the clothes and weapon matched that of the deceased, and the appellant himself was found with unexplained injuries, including injuries on the private parts. These circumstances formed a coherent and complete chain pointing to the appellant and excluded any reasonable hypothesis inconsistent with guilt.

Conclusion: The conviction for the offences under Sections 376 and 302 of the Indian Penal Code, 1860 was rightly sustained.

Issue (ii): Whether the appellant was a juvenile on the date of occurrence and entitled to the benefit of the juvenile justice regime, warranting setting aside of the sentence.

Analysis: In the absence of documentary proof of age, the Court relied on the medical board's radiological and clinical assessment. The board assessed the appellant's age at about 33 years on the date of examination, which placed him below 18 years on the date of occurrence even on the appellant's own working of the estimate. Applying Rule 12(3)(b) of the Juvenile Justice (Care and Protection of Children) Rules, 2007, the Court accepted the age estimate and treated the appellant as a juvenile at the relevant time.

Conclusion: The appellant was held to be a juvenile on the date of occurrence and was entitled to the consequential benefit; the sentence was set aside.

Final Conclusion: The appeal succeeded only to the extent that the conviction was maintained but the sentence was annulled, resulting in the appellant's release unless required in another case.

Ratio Decidendi: A conviction may be sustained on circumstantial evidence where the circumstances form a complete chain pointing unerringly to the accused, and in juvenile age determination, a duly constituted medical board's opinion may be accepted under the prescribed rules where no documentary proof is available.

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