Chetan v. State of Karnataka
“Last-Seen Doctrine Extended When Supported by Forensic Evidence”
TL;DR
The Supreme Court upheld the murder conviction based on circumstantial evidence, clarifying that the temporal proximity requirement in the "last-seen together" doctrine is elastic, not rigid, when supported by strong forensic evidence and recovery of stolen items.
The Bottom Line
You can be convicted for murder even without an eyewitness if the chain of circumstantial evidence - like being last seen with the victim, recovery of murder weapon, and forensic matches - points only to you.
Case Timeline
The journey from FIR to Supreme Court verdict
Last Seen Together
Chetan and Vikram last seen going hunting together
Last Seen Together
Chetan and Vikram last seen going hunting together
Body Discovered
Vikram's body found shot dead in sugarcane field
Body Discovered
Vikram's body found shot dead in sugarcane field
Recovery of Evidence
Accused led to recovery of gun, cartridges, gold chain, mobile
Recovery of Evidence
Accused led to recovery of gun, cartridges, gold chain, mobile
Forensic Examination
Ballistic report matched weapon to pellets in deceased's skull
Forensic Examination
Ballistic report matched weapon to pellets in deceased's skull
Trial Court Conviction
Convicted under Section 302 IPC and Arms Act
Trial Court Conviction
Convicted under Section 302 IPC and Arms Act
Sessions Court
Conviction upheld on appeal
Sessions Court
Conviction upheld on appeal
Supreme Court Judgment
Appeal dismissed; conviction confirmed
Supreme Court Judgment
Appeal dismissed; conviction confirmed
The Story
The accused Chetan and the deceased Vikram Sinde were friends. Chetan owed Rs. 4,000 to Vikram. On 10th July 2006, Chetan called Vikram to go hunting together. They were last seen together on that date.
Vikram Sinde was found shot dead in a sugarcane field near Mahishyal bus stand, Karnataka. His body was discovered with gunshot wounds to the head. There was no eyewitness to the actual shooting.
The prosecution's case was entirely based on circumstantial evidence: 1. Both were last seen together on the day of the incident 2. Chetan led the police to recover the DBBL gun, live cartridges, and empty cartridges 3. He also led to recovery of Vikram's gold chain and mobile phone 4. Ballistic examination confirmed the gun was operational 5. The shells had been discharged from the recovered gun 6. Pellets and wads found in the deceased's skull matched the weapon 7. After the crime, Chetan absconded
The Trial Court convicted Chetan. The Sessions Court upheld the conviction. Chetan appealed to the Supreme Court challenging the conviction based on circumstantial evidence.
Legal Issues
Click each question to reveal the Supreme Court's answer
Arguments
The battle of arguments before the Supreme Court
Petitioner
Vihaan Kumar
No eyewitness evidence
There was no eyewitness who saw the appellant shooting the deceased.
Gap in last-seen evidence
The time gap between last sighting and discovery of body was significant, breaking the chain.
Motive not proved
The prosecution failed to adequately prove the motive of Rs. 4,000 debt.
Respondent
State of Haryana
Complete chain of circumstances
The chain of circumstantial evidence was unbroken - last seen, recovery of weapon, forensic match, stolen items, absconding.
Forensic corroboration
Ballistic evidence conclusively linked the recovered weapon to the crime.
Recovery at instance of accused
The accused himself led to recovery of murder weapon and victim's belongings.
Court's Analysis
How the Court reasoned its decision
The Supreme Court examined the completeness of the circumstantial evidence chain. It held that the last-seen theory's temporal proximity requirement is elastic, not rigid, especially when corroborated by strong forensic evidence and recovery of incriminating articles.
In cases of circumstantial evidence, the evidentiary chain must be so complete that only one conclusion can be drawn from it—that the accused committed the offense.
Para Para 15
Restates the standard for circumstantial evidence cases.
The temporal proximity requirement in the last-seen rule is elastic, not rigid.
Para Para 22
Clarifies flexibility in applying last-seen doctrine.
On the point of motive, even if it was not fully proved, it does not affect the case if other evidence clearly proves guilt.
Para Para 28
Motive is relevant but not essential when other evidence is strong.
The ballistic examination confirmed the gun was operational, the shells had been discharged from the recovered gun, and pellets and wads located in the skull of the deceased matched the weapon.
Para Para 32
Forensic evidence provided conclusive link to the accused.
The Verdict
Relief Granted
No relief to appellant; murder conviction and sentence confirmed.
Directions Issued
- Bail bonds cancelled; appellant to surrender forthwith
- Appellant to undergo remaining period of sentence
- Conviction based on complete chain of circumstantial evidence upheld
Key Legal Principles Established
Circumstantial evidence can sustain conviction if chain is complete
Chain must point only to guilt of accused, excluding other possibilities
Last-seen theory temporal proximity is elastic when forensic evidence corroborates
Recovery of weapon and stolen items at instance of accused is strong evidence
Motive need not be proved if other evidence is conclusive
Absconding after crime is incriminating conduct
Key Takeaways
What different people should know from this case
- You can be convicted for murder even without anyone seeing you do it
- If evidence like the murder weapon and victim's belongings are found with you, that's strong proof
- Running away after a crime is considered evidence against you
- Modern forensic science can link you to a crime even without witnesses
Legal Framework
Applicable laws and provisions
Statutory Provisions
Section 302
Indian Penal Code, 1860
“Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
Relevance: Substantive offense of murder.
Section 27
Indian Evidence Act, 1872
“When any fact is deposed to as discovered in consequence of information received from a person accused of any offence, so much of such information as relates distinctly to the fact thereby discovered, may be proved.”
Relevance: Governs admissibility of recovery evidence.
Section 8
Indian Evidence Act, 1872
“Any fact is relevant which shows or constitutes a motive or preparation for any fact in issue or relevant fact.”
Relevance: Motive and conduct are relevant facts.
Related Cases & Precedents
Sharad Birdhichand Sarda v. State of Maharashtra
followed(1984) 4 SCC 116
Five golden principles for circumstantial evidence cases.
Padala Veera Reddy v. State of A.P.
cited(1989) 3 SCC 614
On last-seen theory requirements.
Watch & Learn
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