Broken Chains of Circumstantial Evidence: Acquittal in a Child Sexual Assault and Murder Case
In this criminal appeal, the appellant challenged his conviction and sentence of life imprisonment under Sections 376(2)(i), 302, and 201 of the Indian Penal Code, 1860, as well as Sections 4 and 6 of the Protection of Children from Sexual Offences Act, 2012, which had been concurrently upheld by the Sessions Court and the High Court of Sikkim. The Supreme Court reviewed the circumstantial evidence presented by the prosecution—including the “last seen” theory, Section 27 recoveries, DNA reports, FSL results, and the appellant’s statement under Section 313 of the Code of Criminal Procedure, 1973. Finding that the chain of circumstances was broken and incomplete at multiple points, and that the DNA and forensic reports did not link the appellant or recovered remains to the victim, the Court gave the appellant the benefit of the doubt, set aside the lower court judgments, and ordered his immediate acquittal.
2026 INSC 1073: Santosh Gurung v. State of Sikkim (D.O.J. 01.10.2026)
Shadows of Circumstantial Doubt: Upholding Acquittal in a Double Murder Case
In this criminal appeal filed by the State of Himachal Pradesh, the Supreme Court examined whether the High Court was justified in setting aside the trial court’s judgment convicting and sentencing the respondent-accused under Section 302 of the Indian Penal Code, 1860, for the double murder of her stepmother and minor stepbrother. The prosecution relied heavily on circumstantial evidence, including the “last seen” theory, taxi travel logs, hotel stays, recovery of keys and a mobile phone via disclosure, and DNA profile matching of bloodstains found at the crime scene. Upon re-evaluating the record, the Supreme Court held that the prosecution failed to establish a complete and unbroken chain of circumstances pointing exclusively to the guilt of the accused. Finding serious investigational lapses—such as omitted mobile tower locations, untrustworthy corroborative witnesses, and non-conclusive forensic links—the Court upheld the High Court’s acquittal and dismissed the appeal.
2026 INSC 1074: State of Himachal Pradesh v. Anchla @ Chanchla (D.O.J. 01.10.2026)
Consensual Relationship Beyond Future Promises: Rape Case Stemming from Failed Marriage Proposal Quashed
The Supreme Court of India allowed a criminal appeal and quashed the charge-sheet and proceedings in Sessions Case No. 216 of 2025 pending against the appellant before the Additional Sessions Judge (FTC), Bilaspur, Chhattisgarh. The case was registered on allegations of rape/sexual exploitation under the false promise of marriage following the breakdown of a three-year consensual relationship. A Division Bench comprising Justice J.B. Pardiwala and Justice K. Vinod Chandran held that a long-standing, voluntary physical relationship between two educated adults cannot be given a criminal color under the guise of “misconception of fact” under Section 90 IPC simply because a future marriage proposal fell through. The Court emphasized that criminal prosecution cannot be reduced to a strong-arm tactic to force marriage.
2026 INSC 1081: Martanda Singh v. State of Chhattisgarh and Anr. (D.O.J. 01.10.2026)
Counter-Blast Allegations & Delayed Claims: Supreme Court Quashes “Rape on Promise of Marriage” FIR
The Supreme Court of India allowed a criminal appeal and quashed FIR No. 326 of 2025, Charge Sheet No. 5 of 2026, and all consequent proceedings in Criminal Case No. 147 of 2026 against the appellant and co-accused. A Division Bench comprising Justice J. B. Pardiwala and Justice K. Vinod Chandran evaluated the matter under the four-step framework for quashing criminal proceedings established in Pradeep Kumar Kesarwani v. State of U.P.. The Court found that the allegations of rape, delayed by over a year and a half, were brought as a counter-blast to prior extortion complaints filed by the appellant. It held that the criminal prosecution was initiated primarily to coerce the appellant into marriage, which constitutes a clear abuse of the judicial process.
2026 INSC 1082: Sachin Gupta v. The State of Chhattisgarh and Anr. (D.O.J. 01.10.2026)
Identification of Absconding Accused: Supreme Court Overrules Preemptory Quashing in NDPS Cases
The Supreme Court of India allowed an appeal filed by the State of Karnataka, setting aside a High Court order that had quashed criminal proceedings under Section 20(b)(ii)(C) of the NDPS Act against an absconding accused (Accused No. 3). A Division Bench of Justice J.B. Pardiwala and Justice K. Vinod Chandran held that precedents such as Tofan Singh, Pallulabid Ahmad Arimutta, Balwinder Singh, and Firdoskhan Khurshidkhan—which rule that confessional/disclosure statements lack evidentiary value for conviction or bail—do not justify the premature quashing of a pending prosecution against an absconder at the initial stage. The Court clarified that co-accused disclosures revealing the identity of a suspect who fled the spot serve as valid investigative leads, and restored the proceedings to the Special Court while granting the accused liberty to seek discharge at the appropriate stage.
