Circumstantial evidence in a criminal trial: Supreme Court Judgment in Vinod Kumar v. State (Govt. of NCT of Delhi) 2014

Introduction The Supreme Court of India, in its judgment in Vinod Kumar v. State (Govt. of NCT of Delhi) [2025 INSC 209], dealt with crucial aspects of circumstantial evidence in a criminal trial. The case revolved around the conviction of the appellant for murder under Section 302 of the Indian Penal Code (IPC) and raised significant legal questions regarding evidentiary gaps, the doctrine of ‘last seen together,’ and procedural errors in trial proceedings.

Factual Background:

The appellant, Vinod Kumar, was convicted by the Sessions Court and the High Court of Delhi for the murder of Dharminder, a neighbor. On July 12, 1995, the appellant allegedly took the deceased from his home, after which the deceased was found dead with a rope tied around his neck and his hands bound. The prosecution’s case relied solely on circumstantial evidence, as there were no eyewitnesses.

The trial court and the High Court relied on the following key circumstances to convict the appellant:

• The deceased was last seen with the appellant by his mother (PW-3).
• The appellant provided evasive answers about the deceased’s whereabouts.
• The appellant absconded when the missing person’s report was filed.
• Bloodstained clothes were recovered at the instance of the appellant.
• The appellant had unexplained injuries.

Legal Contentions:

The appellant’s counsel argued that:

1. The evidence of PW-3 was inconsistent, with several omissions and contradictions.
2. The ‘last seen together’ theory was not conclusively proven.
3. The evasive replies allegedly given by the appellant were not sufficiently established.
4. The prosecution failed to prove a complete chain of circumstances to establish guilt beyond a reasonable doubt.
5. The trial court improperly recorded contradictions in witness statements without following due procedure.

The prosecution contended that the cumulative effect of the circumstances established the appellant’s guilt and justified the conviction.

Supreme Court’s Analysis and Decision:

The Supreme Court scrutinized the evidence and found significant gaps in the prosecution’s case:

1. Last Seen Theory: The Court held that the testimony of PW-3 was unreliable due to multiple inconsistencies. Additionally, PW-1 (the father of the deceased) was not an eyewitness to the deceased leaving with the appellant.
2. Evasive Replies: The Court found that the allegation of evasive answers by the appellant was not adequately supported by evidence.
3. Absconding and Recovery of Evidence: The appellant’s alleged absconding was not sufficient to establish guilt, and the recovery of bloodstained clothes alone could not be conclusive proof of involvement.
4. Deficiencies in Trial Court Procedure: The Court criticized the trial court for not following proper procedures in marking and proving contradictions in witness statements.

Conclusion The Supreme Court set aside the conviction, holding that the prosecution failed to establish a complete chain of circumstances to prove the guilt of the appellant beyond a reasonable doubt. The judgment reaffirms the principle that circumstantial evidence must be conclusive and leave no room for any alternative hypothesis of innocence.

References

1. Vinod Kumar v. State (Govt. of NCT of Delhi), Criminal Appeal No. 2482 of 2014, 2025 INSC 209.
2. Indian Penal Code, 1860.
3. Code of Criminal Procedure, 1973.
4. Indian Evidence Act, 1872.