Supreme Court Acquits Manoj in 2004 Murder Case, Curbing Reliance on 'Last Seen' Theory

The bench held that misapplication of Evidence Act Section 106 left gaps in proof that required giving the appellant the benefit of doubt.

Overview

The Supreme Court set aside the conviction and life sentence, with Justices Sanjay Karol and Prashant Kumar Mishra acquitting Manoj alias Munna.
The judgment reiterates that a conviction based on indirect proof is permissible only when the chain of circumstances is complete and wholly inconsistent with innocence.
The Court ruled that being last seen with the deceased cannot by itself sustain guilt in a case built entirely on indirect proof, citing Kanhaiya Lal v. State of Rajasthan.
It found the prosecution relied on an alleged tractor-theft motive and last-seen accounts without corroboration linking Manoj to the killing or disposal of evidence.
The Court clarified that Section 106 of the Evidence Act operates only after the State first establishes a reasonable inference, faulting the lower courts for shifting the burden prematurely.