Supreme Court Acquits Man in Chhattisgarh Murder Case, Finds Section 27 Recoveries Unreliable

News Citation : 2026 LN (SC) 325

April 7, 2026 : The Supreme Court of India has set aside the conviction of a man sentenced to life imprisonment for murder in Chhattisgarh, holding that the prosecution failed to establish a legally reliable chain of circumstantial evidence, particularly with respect to recoveries made under Section 27 of the Evidence Act.

In its judgment delivered on April 7, 2026, in Gautam Satnami v. State of Chhattisgarh, a bench comprising Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi allowed the appeal and acquitted the appellant of the charge under Section 302 IPC.

The case arose from a 2011 murder in Rajnandgaon district, where the Trial Court had convicted the appellant, a decision later affirmed by the Chhattisgarh High Court. The prosecution’s case rested entirely on circumstantial evidence, including the alleged recovery of a blood-stained axe and clothes based on disclosure statements, and the recovery of the appellant’s driving licence from the crime scene.

The Supreme Court found serious flaws in the prosecution’s case. It noted that although forensic reports confirmed the presence of human blood on the seized weapons and clothes, there was no determination of blood group linking it to the deceased. Further, while hair samples found on the axe showed similarities with those recovered from the scene, no conclusive opinion established that they belonged to the deceased. Importantly, the prosecution failed to establish any definitive connection between the alleged weapon and the injuries sustained by the victim.

The Court also expressed doubt over the credibility of recovery proceedings under Section 27. Key witnesses to the disclosure statements and seizure memos either turned hostile or failed to support the prosecution’s version. In some instances, signatures on seizure documents were obtained later rather than at the time and place of recovery, raising serious procedural concerns.

On the issue of “last seen” evidence, the Court held that the testimony placing the appellant near the crime scene at night was unreliable due to poor visibility conditions and lack of corroboration. It further observed that even if accepted, such evidence merely established presence in the vicinity and not involvement in the crime.

A significant factor in the Court’s reasoning was the acquittal of a co-accused by the Trial Court on similar evidence. Applying the principle of parity, the bench held that it would be unsafe to sustain the appellant’s conviction when the evidence against both accused was materially identical.

The Court reiterated that in cases based on circumstantial evidence, every link in the chain must be firmly established and must exclude all hypotheses except guilt. Mere suspicion, however strong, cannot substitute proof.

Finding that the prosecution failed to prove the case beyond reasonable doubt, the Court held the conviction unsustainable and extended the benefit of doubt to the appellant, resulting in his acquittal.

Case Reference : Criminal Appeal No. 1782 of 2026 (Arising out of SLP (Criminal) No. 11080 of 2022), Gautam Satnami v. State of Chhattisgarh