Two lovers went missing. Nine days later, their bodies were found hanging. The Supreme Court just acquitted the man convicted of their murder.
The prosecution said Chandrapal killed the couple and staged a suicide. But the doctor couldn't say if it was murder. And the key evidence? A jailhouse confession from a co-accused who was himself acquitted.
9
days.
The prosecution said Chandrapal killed the couple and staged a suicide. But the doctor couldn't say if it was murder. And the key evidence? A jailhouse confession from a co-accused who was himself acquitted.
Two lovers from different castes disappeared. Nine days later, their bodies were found hanging from a tree. The police called it suicide. The trial court called it murder. The Supreme Court just called it—not proven.
On a December morning in 1994, Kumari Brindabai and Kanhaiya Siddar walked out of their village in Chhattisgarh and never came back. Nine days later, their decomposed bodies were found hanging from a cashew tree. The rope around their necks looked like a suicide. But Brindabai's father Bhagirathi and her uncle Chandrapal had opposed the relationship—the couple were from different castes. The prosecution built a case: Chandrapal and three others had murdered the lovers, kept the bodies for two days, then staged the hanging. The trial court agreed. The High Court partly agreed. The Supreme Court just pulled the entire case apart, piece by piece.
The procedural journey: three courts, three outcomes
This case, Chandrapal v. State of Chhattisgarh, took nearly three decades to reach its final destination. It began in the First Additional Sessions Court in Raipur, Chhattisgarh. On 3 August 1998, the trial court convicted all four accused—Chandrapal, Videshi, and two others—under Sections 302 and 34 of the Indian Penal Code (murder with common intention) and under Section 201 (causing disappearance of evidence of an offence). The court acquitted them under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, but that was a minor footnote. The core finding: all four had conspired to kill the lovers and stage a suicide.
The four men appealed to the High Court of Chhattisgarh at Bilaspur. The High Court delivered a split verdict. It acquitted three of the co-accused of murder entirely, but confirmed their conviction under Section 201 for destroying evidence. Only Chandrapal's murder conviction under Section 302/34 was upheld. The logic was puzzling: if the same evidence—the same extra-judicial confession, the same 'last seen' testimony—was insufficient to convict three men, how could it be sufficient to convict the fourth? The High Court did not answer that question. Chandrapal took his appeal to the Supreme Court of India.
On 27 May 2022, a bench of Justice Dhananjaya Y. Chandrachud and Justice Bela M. Trivedi heard Criminal Appeal No. 378 of 2015. The Supreme Court allowed the appeal. Chandrapal was acquitted and directed to be set free forthwith.
When the post-mortem doctor couldn't say
The prosecution's entire case rested on one fact: that the two lovers were murdered. But the doctor who conducted the post-mortem could not confirm this. The bodies were too decomposed. The doctor's opinion was that the deaths appeared suicidal—the ligature marks, the position of the ropes, the absence of other injuries all pointed toward hanging by their own hands. The doctor could not say it was homicide.
This is where the case should have ended. In a murder trial, the prosecution must first prove that a murder happened. The Supreme Court has repeatedly held—in cases like Sharad Birdhichand Sarda v. State of Maharashtra (1984) and State of M.P. Through CBI v. Paltan Mallah (2005)—that the factum of homicidal death is a primary, foundational fact. If the evidence falls short of proving homicide, and the possibility of suicide cannot be ruled out, a conviction under Section 302 cannot be sustained. But the trial court and the High Court built their convictions anyway—on two pieces of evidence: a jailhouse confession from a co-accused, and the fact that someone had last seen the couple alive near the village.
The confession that convicted no one else
The key evidence against Chandrapal was an extra judicial confession (a confession made outside a courtroom, not recorded by a magistrate) given by a co-accused named Videshi. Videshi allegedly told a witness that Chandrapal had planned the murders. Under Section 30 of the Evidence Act (a provision that allows a court to consider a confession made by one accused person against another accused person in the same trial), this confession could be used against Chandrapal.
But here's the problem: the same confession was used against three other co-accused. The High Court acquitted all three of them of murder. If the confession was too weak to convict Videshi's own co-accused, how could it be strong enough to convict Chandrapal alone? The Supreme Court found this inconsistency fatal. The court cited its own precedents—Shivaji Sahabrao Bobade v. State of Maharashtra (1973), Pancho v. State of Haryana (2011), Jagroop Singh v. State of Punjab (2012)—to reiterate that an extra judicial confession is inherently weak evidence. It is not made under oath, not tested by cross-examination, and often motivated by pressure or hope of leniency. Under Section 30, such a confession is admissible only as corroborative evidence; absent substantive evidence against the accused, it loses all significance and cannot form the basis of a conviction. The court held that unless such a confession inspires complete confidence or is corroborated by other solid evidence of a clinching nature, it cannot sustain a murder conviction.
The 'last seen' theory that didn't fit
The prosecution also relied on the 'last seen together' doctrine (a legal inference that if a person was last seen with the accused and the body is found soon after, the accused may be responsible for the death). A witness claimed to have seen the couple near the village on the day they went missing—2 December 1994. But the bodies were found nine days later, on 11 December. The Supreme Court held that the time gap between the last sighting and the discovery of the bodies was far too large to exclude the possibility that someone else—or the couple themselves—had caused the deaths. The court cited Sahadevan v. State of Tamil Nadu (2012) and S.K. Yusuf v. State of West Bengal (2011) for the proposition that the 'last seen' theory applies only when the gap is so small that no other explanation is reasonably possible. Nine days is not a small gap. In the absence of other links in the chain of circumstantial evidence, the accused cannot be convicted solely on the basis of 'last seen together'—even if the prosecution witness's version is believed.
The chain that had missing links
The Supreme Court applied the standard test for circumstantial evidence cases, drawn from the landmark judgment in Sharad Birdhichand Sarda v. State of Maharashtra (1984). For a conviction based on circumstances, five conditions must be met: the circumstances must be fully proved (not just 'may be' proved), they must be consistent only with guilt, they must be of a conclusive nature, they must exclude every other hypothesis except guilt, and they must form a complete chain leaving no reasonable ground for a conclusion consistent with innocence. The court also cited Bodhraj v. State of Jammu and Kashmir (2002) for the same principle.
The chain in this case had gaping holes. The medical evidence could not confirm homicide. The extra judicial confession was unreliable and had been rejected for three other accused. The 'last seen' theory was stretched beyond its limits. The prosecution had not established the primary fact—that a murder had occurred at all. Without that, the entire case collapsed. The Supreme Court did not need to examine every piece of evidence; it needed only to see that the foundational fact was missing. The rest of the structure fell on its own.
What the Supreme Court actually decided
The bench of Justice Dhananjaya Y. Chandrachud and Justice Bela M. Trivedi allowed Chandrapal's appeal and ordered his immediate release. The court held that the prosecution had failed to prove homicidal death as a foundational fact. The extra judicial confession of a co-accused, being weak evidence, could not sustain a conviction without substantive corroboration—especially when the same evidence was found insufficient to convict the other three accused. The 'last seen together' theory was inapplicable given the ten-day gap between the last sighting and the discovery of the bodies.
Chandrapal's conviction under Section 302 (punishment for murder) and Section 34 (acts done in furtherance of common intention) was quashed. His conviction under Section 201 (causing disappearance of evidence of an offence) was left undisturbed—but since the murder conviction fell, the sentence for that lesser offence had already been served. The three co-accused, whose murder convictions had already been overturned by the High Court, remained convicted only under Section 201. The SC/ST Act acquittal from the trial court was not disturbed.
THE PLAY: In a murder trial, if the medical evidence cannot confirm that the death was homicidal, the prosecution has no case—no amount of circumstantial evidence can fill that foundational gap. An extra judicial confession is too weak to stand alone, and the 'last seen' theory cannot bridge a ten-day gap.
The two lovers were never given a name in the judgment beyond their caste and their relationship. The tree they hung from was a cashew tree. The doctor could not say what happened. And the Supreme Court ended where the evidence began: with two bodies hanging from a branch, and no one able to say who put them there. Chandrapal walked out of prison a free man—not because the court believed he was innocent, but because the prosecution had failed to prove he was guilty.