Facts: The deceased, a sixteen-year-old girl, was induced by Accused No. 3 (Santosh) to leave her home in Wadala and stay at a flat in Nalasopara. Between April and May 2014, the three appellants repeatedly committed gang rape on her. When she resisted being sent to Uttar Pradesh and attempted to seek help through a friend (PW-25), Accused Nos. 1 and 2 murdered her by strangulation and blunt force trauma. They packed her body in a trolley bag and transported it via taxi and rickshaw to Talegaon Railway Station, where it was abandoned. The crime was detected after a SIM card, concealed by the victim in her undergarments, led police to PW-25, who identified the victim and the accused. Forensic evidence matched nylon rope found in the flat of Accused No. 1 with the rope used to tie the victim's body.
Procedural Posture: The Special POCSO Court at Pune convicted the appellants for murder, gang rape, kidnapping, and destruction of evidence. They were sentenced to life imprisonment for the remainder of their natural lives. The appellants challenged this conviction and the legality of the "natural life" sentence before the High Court of Bombay.
Issue: 1. Whether the prosecution established a complete chain of circumstantial evidence to sustain the conviction. 2. Whether a Trial Court has the power to impose a sentence of life imprisonment for the "remainder of natural life" under Section 302 of the IPC.
Holding: 1. Yes, the conviction is sustained as the chain of circumstances is complete and unerringly points to the guilt of the accused. 2. No, a Trial Court cannot impose a "natural life" sentence under Section 302, but the High Court possesses the jurisdiction to confirm or impose such a sentence.
Reasoning: The Court relied on the testimony of PW-25, noting that statements made by the deceased regarding her torture and the identity of her captors were admissible under Section 32(1) of the Indian Evidence Act as circumstances of the transaction resulting in death. Corroborative evidence included Call Detail Records (CDR) and IMEI matching, which tracked the appellants' movements from Mumbai to Pune. On sentencing, the Court followed the Supreme Court's precedents in "Gauri Shankar v. State of Punjab", holding that while only the High Court or Supreme Court can specify a "remainder of natural life" term for murder under Section 302, such a sentence is expressly permitted for gang rape under Section 376-D. Given the extreme depravity and brutality of the crime against a minor, the High Court confirmed the natural life sentence.