Indian Circumstantial Evidence History

Introduction 

Circumstantial evidence is evidence that suggests a fact or a set of facts from which a fact-finder can infer another fact. It is indirect evidence and does not directly prove the fact in question. For example, if a person is found with a weapon at the scene of a crime and has no explanation for it, this would be circumstantial evidence that they were involved in the crime.

Circumstantial evidence, also known as indirect evidence, is evidence that relies on an inference to connect it to a conclusion of fact. In Indian law, circumstantial evidence is considered to be of equal importance as direct evidence. The Indian Evidence Act, 1872 defines circumstantial evidence as “evidence of facts in issue or relevant facts from which, either by itself or in conjunction with other evidence, the existence or non-existence of any fact in issue can be inferred.” The Indian judiciary has a long history of using circumstantial evidence in criminal cases. In the case of Hanumant v. State of Madhya Pradesh (1952), the Supreme Court of India held that circumstantial evidence can be the basis of a conviction if it is consistent with the guilt of the accused and inconsistent with any other rational hypothesis. This principle, known as the "Hanumant test," has been applied in many subsequent cases.

In recent years, the Indian judiciary has emphasized the importance of considering the cumulative effect of all the circumstantial evidence in a case, rather than focusing on individual pieces of evidence. In the case of State of U.P. v. Satish (2010), the Supreme Court of India held that “in a case based on circumstantial evidence, the circumstances from which the conclusion of guilt is to be drawn should be in close proximity with the principal fact sought to be inferred from those circumstances.”

It is also important to note that circumstantial evidence can be just as strong as direct evidence, and in some cases can be even stronger. In criminal cases, circumstantial evidence alone can be enough to secure a conviction. However, it is important that the evidence is properly presented and evaluated to ensure that the fact-finder is not basing their decision on faulty inferences or assumptions.

Advantages of circumstantial evidence 

There are several advantages of using circumstantial evidence in legal proceedings:

• Circumstantial evidence can be more reliable than direct evidence. Circumstantial evidence is often collected and presented in a more systematic way, which can make it more reliable than direct evidence, which can be subject to human error or bias.
• Circumstantial evidence can be used to establish a chain of events. By piecing together different pieces of circumstantial evidence, it can be possible to establish a clear sequence of events that led to the crime or incident in question.
• Circumstantial evidence can be used to fill in gaps in direct evidence. In some cases, there may not be any direct evidence available, but circumstantial evidence can be used to infer what happened.
• Circumstantial evidence can be used to establish motive. By looking at the circumstances surrounding the crime, it can be possible to infer the possible motives of the perpetrator.
• Circumstantial evidence is not dependent on the testimony of a witness. Unlike direct evidence, which relies on the testimony of a witness, circumstantial evidence can be established through physical evidence, such as fingerprints, DNA, etc, and is not dependent on the testimony of a witness who may not be reliable or available.

Disadvantages of using circumstantial evidence 

There are several disadvantages of using circumstantial evidence in legal proceedings:

• Circumstantial evidence can be subject to interpretation. Different people may interpret the same set of circumstances in different ways, which can make it difficult to establish a clear chain of events or to infer the perpetrator's motives.
• Circumstantial evidence can be less convincing than direct evidence. Direct evidence, such as a witness's testimony, can be more convincing to a jury than circumstantial evidence, which relies on inferences and assumptions.
• Circumstantial evidence can be open to alternative explanations. There may be multiple explanations for the same set of circumstances, which can make it difficult to infer the perpetrator's guilt.
• Circumstantial evidence may be weak, circumstantial evidence may be weak and inconclusive, which may not be sufficient to prove guilt beyond a reasonable doubt.
• Circumstantial evidence may have been obtained illegally or obtained through means that would not be admissible in court, thus it can be challenged on the ground of violation of constitutional rights.

One landmark judgement in India that dealt with circumstantial evidence is the case of Hanumant v. State of Madhya Pradesh, which was decided by the Supreme Court of India in 1952. This case established the "doctrine of circumstantial evidence" which is commonly known as "Hanumant's doctrine". In this case, the accused was convicted on the basis of circumstantial evidence for the murder of his wife. The Supreme Court laid down a set of guidelines for the evaluation of circumstantial evidence, which are commonly referred to as the "Hanumant's doctrine". These guidelines are:

• The circumstances from which the conclusion of guilt is to be formed must be completely established, and they must be of a conclusive nature and tendency.
• They should exclude every possible hypothesis except the one to be proved.
• There must be a chain of evidence so thorough that it leaves no reasonable room for a finding consistent with the accused's innocence and must demonstrate that the act must have been committed by the accused in all human probability.

These guidelines laid down in Hanumant case are widely followed in India and are considered as a standard for evaluating circumstantial evidence in criminal trials. This case is considered as one of the most important cases in Indian criminal jurisprudence, as it lays down principles for the evaluation of circumstantial evidence, which are followed till date.

Landmark cases relating to circumstantial evidence in India 

There are several landmark cases in India that have dealt with circumstantial evidence and have established important principles for evaluating such evidence. Some of the most notable cases include:

• Hanumant v. State of Madhya Pradesh (1952) - This case established the "doctrine of circumstantial evidence" which is commonly known as "Hanumant's doctrine", which lays down guidelines for the evaluation of circumstantial evidence in criminal trials.
• Sharad Birdhichand Sarda v. State of Maharashtra (1984) - This case dealt with the question of whether the prosecution can prove its case solely on the basis of circumstantial evidence. The Supreme Court held that circumstantial evidence can be the sole basis for conviction, provided the circumstances are fully established and are consistent only with the hypothesis of the guilt of the accused.
• State of U.P. v. Satish (2010) - This case dealt with the question of how to evaluate circumstantial evidence when there is a delay in lodging the FIR. The Supreme Court held that delay in lodging the FIR will not affect the credibility of the prosecution's case if the circumstantial evidence is reliable and consistent with the guilt of the accused.
• Rajendra Pralhadrao Wasnik v. State of Maharashtra (2013) - This case dealt with the question of how to evaluate circumstantial evidence when there is a possibility of a false implication of the accused. The Supreme Court held that the prosecution must prove that the possibility of a false implication is remote and that the circumstantial evidence is consistent with the guilt of the accused.
• State of Gujarat v. Kishorebhai Nathalal Patel (2017) - This case dealt with the question of how to evaluate circumstantial evidence when the prosecution relies on the motive of the accused to establish guilt. The Supreme Court held that motive alone cannot be the sole basis for conviction, but it can be considered as a piece of evidence along with other circumstantial evidence.

Conclusion 

Circumstantial evidence is important because it can be used to infer a fact that is not directly observable. It can be used to establish a chain of events or a pattern of behaviour that can be used to support or refute a claim. It can also be used to establish motive, intent, or knowledge. In some cases, circumstantial evidence can be just as convincing as direct evidence, the Indian judiciary has time and time again from its judgment has held the importance of circumstantial evidence and it is an important aspect of judicial proceedings. must be a chain of evidence so thorough that it leaves no reasonable room for a finding consistent with the accused's innocence and must demonstrate that the act must have been committed by the accused in all human probability.