State of Madhya Pradesh v. Janved Singh 2025 INSC 1229 - False Explanation By Accused - Murder

Criminal Trial - Murder Case - Circumstantial Evidence - When an accused offers a false explanation regarding the cause of death which takes place within the confines of his house, such falsity becomes an additional link in the chain of circumstances pointing to the guilt of the accused- A conviction for murder can solely rest on circumstantial evidence if the chain of circumstances is complete and consistent only with hypothesis of the guilt of the accused. (Para 12- 14)

Indian Evidence Act 1872 - Section 106 is not intended to relieve the prosecution of its duty to prove the case. On the contrary, it is designed to meet exceptional cases in which it would be impossible, or at any rate, disproportionately difficult for the prosecution to establish facts within the knowledge of the accused which he can prove without any difficulty or inconvenience. The word “especially” used in Section 106 of the Evidence Act means the facts which are pre-eminently or exceptionally within the knowledge of the accused . The traditional rule relating to burden of proof of the prosecution cannot be allowed to be wrapped in a pedantic coverage, the offenders in serious offences would be the major beneficiaries and the society would be the casualty. (Para 13)

Code of Criminal Procedure 1973 - Section 372- Criminal Appeal - while dealing with an appeal against the acquittal the reasons which weighed with the Trial Court must be dealt with. The normal presumption of innocence gets reinforced with an order of acquittal. If two views are possible from the evidence on record, the appellate court must be extremely slow in interfering with an appeal against an order of acquittal. (Para 15)

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