Facts: The appellant, Raju Raghu Sadavarte, was convicted by the Additional Sessions Judge under Sections 302 (murder) and 201 (causing disappearance of evidence) of the Indian Penal Code (IPC) for the murder of Aniruddha Nalkar. The prosecution's case rested on circumstantial evidence, including a quarrel between the appellant and the deceased, the appellant being last seen with the deceased, an extra-judicial confession to PW2, and the recovery of a hammer (alleged murder weapon). The appellant denied the charges.
Procedural Posture: The appellant challenged the judgment and order of the Additional Sessions Judge in the High Court of Judicature at Bombay via a criminal appeal.
Issue: Whether the prosecution successfully proved the charges under Sections 302 and 201 of the IPC against the appellant beyond a reasonable doubt, based on the circumstantial evidence presented. Specifically, the court examined the validity of the motive, the 'last seen' circumstance, the extra-judicial confession, and the recovery of the alleged murder weapon.
Holding: The High Court allowed the appeal, set aside the Sessions Court's judgment and order, and acquitted the appellant of all charges.
Reasoning: The Court found that the prosecution failed to establish a complete chain of circumstances beyond a reasonable doubt. The alleged motive (a minor quarrel) was insufficient. The 'last seen' circumstance was weakened by the fact that the appellant and deceased, along with other labourers, resided in the same open space. The extra-judicial confession to PW2 was deemed unreliable due to PW2's delayed disclosure, the appellant's alleged intoxication, and a possible money dispute between them. The recovery of the hammer from a public park, accessible to all, did not establish authorship of concealment by the appellant. Furthermore, the blood group on the hammer was inconclusive, and this finding was not presented to the appellant during his examination under Section 313 of the Criminal Procedure Code (Cr.P.C.), denying him an opportunity to explain it. The court also noted the lack of a proper link in the chain of custody for the deceased's clothes and the failure to examine key witnesses. The benefit of doubt was given to the appellant.