VidhiSangh

Supreme Court of India · 07/04/2026

GAUTAM SATNAMI versus STATE OF CHHATTISGARH

[2026] 4 S.C.R. 417 · 2026 INSC 325

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Summary

A murder conviction resting only on circumstantial evidence was set aside. The 'last seen' witness was possibly interested and his identification at night was doubtful. The axe recovery was not linked to the deceased's injuries, and the co-accused had been acquitted on the same recovery evidence. The licence recovery, the prior threat and the motive were not established. The appellant was given the benefit of doubt.

Issues

  1. Whether the scope for interference under Article 136 against concurrent findings permitted re-examination of the circumstantial evidence.
  2. Whether the 'last seen' testimony of a witness with hostility towards the appellant could sustain the conviction.
  3. Whether recoveries under Section 27 of the Evidence Act, not linked to the injuries and rejected for the acquitted co-accused, could be relied on against the appellant.
  4. Whether the remaining circumstances (recovery of the driving licence, prior threat, motive) completed the chain.

Provisions considered

Held

Result

Appeal allowed. The judgments of the High Court and the Sessions Judge were set aside as regards the appellant, who was acquitted of the charge under Section 302 IPC; his bail bonds stand discharged.

Judgment PDF: Supreme Court of India, [2026] 4 S.C.R. 417.