Mohamed Sameer Khan v. State 2025 INSC 1269 - Murder Accused Acquitted - Circumstantial Evidence

Circumstantial Evidence - Principles laid down in Karakkattu Muhammed Basheer v. State of Kerala quoted and applied (Para 17)- [Context: While allowing an appeal against conviction in murder case, SC observed: Merely because the medical evidence proves the unfortunate loss of life would not be enough to convict a person since he happened to be in the vicinity. In the absence of any forensic evidence when there is no eyewitness and the case is of circumstantial evidence, benefit would go to the accused -In cases wherein the guilt of the accused is sought to be established by circumstantial evidence, if two views are possible on the evidence adduced in the case, one pointing to the guilt of the accused and the other to his innocence, the view which is favourable to the accused should be adopted- the prosecution has failed to connect the Appellant to the offence through medical or forensic evidence as no blood, hair or skin sample, or fingerprint belonging to him has been found on the body of the deceased, the recovered articles, or at the place of occurrence.]

Case Info

  • Case name: Mohamed Sameer Khan v. State represented by Inspector of Police.
  • Neutral citation: 2025 INSC 1269.
  • Coram: Dipankar Datta, J.; Augustine George Masih, J.
  • Judgment date: October 29, 2025.

Caselaws and citations

  • Karakkattu Muhammed Basheer v. State of Kerala, (2024) 10 SCC 813.
  • Ramreddy Rajesh Khanna Reddy v. State of A.P., (2006) 10 SCC 172; (2006) 3 SCC (Cri) 512.
  • Anil Kumar Singh v. State of Bihar, (2003) 9 SCC 67; 2004 SCC (Cri) 1167.
  • Reddy Sampath Kumar v. State of A.P., (2005) 7 SCC 603; 2005 SCC (Cri) 1710.
  • State of U.P. v. Satish, (2005) 3 SCC 114; 2005 SCC (Cri) 642.
  • Bodhraj v. State of J&K, (2002) 8 SCC 45; 2003 SCC (Cri) 201.
  • Kali Ram v. State of Himachal Pradesh, (1973) 2 SCC 808.

Statutes/laws referred

  • Indian Penal Code, 1860: Sections 302, 449 (read with 457 noted in charges), 376, 394.
  • Code of Criminal Procedure, 1973: Section 313.
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