- The Hon’ble Telangana HC has, in the case of Janapally Anjilaiah vs. The State of AP has held that conviction cannot be based solely on circumstantial evidence, unless the chain of evidence leaves no other conclusion except the accused’s guilt.
- In the instant case, Ananthaiah had lodged a complaint in 2008 that his mother had disappeared after she had gone to have dinner at Mr. Rasheed’s house and later her dead body was found lying near a water tank by Jakkulapally. Later it was pointed out that Anjilaiah had illegal relations with the victim and that is why he was suspected to be behind her death.
- The trial Court had relied on the testimony of PW1 and 2 who said that their mother had gone with the accused to dinner and the trial Court convicted the accused.
- The HC at the outset, clearly declared that the case of the prosecution was solely based on circumstantial evidence, and in such cases. Judges must tread cautiously and not let suspicion take the place of proof.
- In support of its observations, the Court relied upon the decision of the Hon’ble SC in Gargi vs. State of Haryana where the SC held that circumstantial evidence is one where facts are proved from which of fact in issue may be inferred or rendered probable.
- The Court also outlined the doctrine of panchsheel enumerated in Sharad Birdhichand Sharda vs. State of Maharashtra where it was held that the circumstances should be fully established, these circumstances should be consistent only with the hypothesis of guilt, and should be of a consistent nature.
- The Court thus held that the chain of events was not complete in the present case. The Court also held that the extra judicial confession cannot be the sole basis of conviction if the surrounding circumstances create a doubt as to the guilt of the accused.
- Thus, the order of conviction by the Trial Court was set aside.
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