Gautam Satnami, convicted under Section 302 IPC by the Sessions Judge, Rajnandgaon and sentenced to life imprisonment — a finding affirmed by the High Court of Chhattisgarh at Bilaspur on 19.07.2017 — challenged his conviction before the Supreme Court by way of a criminal appeal. The prosecution's case rested entirely on circumstantial evidence: a 'last-seen' testimony by PW-4 (Raja Ram Deshlahare), recovery of a blood-stained axe and clothes pursuant to disclosure statements under Section 27 of the Evidence Act, recovery of the appellant's driving licence from the crime scene, prior enmity, and an alleged threat issued the evening before the murder. Co-accused Dwarika Jangde (accused No. 2) had been acquitted by the Trial Court on the same body of evidence.
The Supreme Court allowed the appeal and set aside the concurrent findings of guilt, acquitting the appellant. The Court found that the 'last-seen' testimony of PW-4 did not inspire confidence: identification was made at night with no street lighting, relying only on a motorcycle headlight and a house whose electricity supply was disputed; PW-4's Section 161 CrPC statement was recorded a full month after the incident despite his having met the Police on the day itself; and cross-examination disclosed that PW-4 and his associates harboured longstanding hostility towards the appellant, making him a plausible 'interested witness' whose uncorroborated testimony could not sustain conviction. The FSL report confirmed only that human blood was present on the seized axes and clothes — blood grouping was not done, no conclusive link was drawn between the hair on the axes and the deceased, and the axes were never shown to the doctor for an opinion on whether they caused the injuries. Witnesses to both the Section 27 memorandums and the seizure memos either turned hostile or admitted signing documents away from the spot. The driving licence was not included in the charge-sheet and its recovery from the scene remained shrouded in doubt.
The Court applied the principle of parity drawn from Javed Shaukat Ali Qureshi v. State of Gujarat, 2023 INSC 829, and reaffirmed in Ram Singh v. State of U.P., 2024 INSC 128 — holding that where similar or identical evidence is ascribed to two accused, one cannot be convicted while the other is acquitted. Once the unreliable 'last-seen' testimony was excluded, the appellant's position was indistinguishable from that of the acquitted accused No. 2. The Court also reiterated the five 'golden principles' for circumstantial evidence from Sharad Birdhi Chand Sarda v. State of Maharashtra, 1984 INSC 121, and clarified that motive, though present, is only a supporting factor and cannot replace a complete chain of evidence. The Court further noted that Article 136 self-imposed constraints do not prevent interference where striking features demolish the prosecution's case, even against concurrent findings.