Introduction:

The Calcutta High Court, in Md. Abdul Mottalab Mia @ Abdul Mottalab v. The State of West Bengal (CRA 614 of 2014), reaffirmed the principles governing conviction based on circumstantial evidence and upheld the life sentence of a man convicted for murdering a woman with whom he had been living. The Division Bench comprising Justice Rajasekhar Mantha and Justice Rai Chattopadhyay dismissed the criminal appeal filed by the appellant challenging the judgment of the Additional Sessions Judge, Alipurduar, delivered in 2014, which had convicted him under Section 302 of the Indian Penal Code and sentenced him to life imprisonment. The case revolved around the death of a woman who had left her matrimonial home due to alleged ill-treatment and later began living with the appellant after he allegedly promised to marry her. The two had rented a room in Jharna Busty in the Jalpaiguri district in November 2010 and were living together for some time before the incident occurred. The prosecution’s case was based entirely on circumstantial evidence, including the “last seen together” principle, the exclusive custody of the victim with the accused, the suspicious conduct of the accused after the incident, and the medical evidence indicating death by strangulation. The case came to light when the victim’s son received a phone call from the appellant claiming that the victim was seriously ill and required urgent medical attention. When the son reached the rented premises, he found the room locked from the outside. Local residents later broke open the door in the presence of the police and discovered the victim lying lifeless on a bed with blood oozing from her nose and mouth. Investigations revealed signs consistent with homicidal strangulation. The trial court found that the chain of circumstances clearly pointed to the guilt of the accused and convicted him for murder. The appellant later challenged the conviction before the High Court, arguing that the evidence against him was insufficient and that the prosecution had failed to prove the case beyond reasonable doubt. After a detailed examination of the facts, the Calcutta High Court concluded that the prosecution had successfully established a complete chain of circumstances which left no room for doubt regarding the guilt of the accused. The Court therefore upheld the conviction and life sentence imposed by the trial court and directed the appellant, who had been released on bail during the pendency of the appeal, to surrender before the trial court within ten days, failing which his bail bonds would stand cancelled.

Arguments of the Appellant:

The appellant challenged the conviction primarily on the ground that the prosecution’s case was based entirely on circumstantial evidence and that the chain of circumstances was incomplete and insufficient to sustain a conviction for murder. Counsel appearing for the appellant argued that in cases based solely on circumstantial evidence, the prosecution must establish every link in the chain of circumstances beyond reasonable doubt so that the evidence leads to only one conclusion—namely the guilt of the accused. According to the appellant, the prosecution had failed to meet this standard in the present case. It was argued that the trial court had relied excessively on assumptions rather than concrete proof while arriving at the conclusion of guilt. The appellant’s counsel contended that the prosecution had failed to produce any eyewitness to the alleged murder and that there was no direct evidence linking the appellant to the death of the victim. It was further submitted that the “last seen together” theory alone could not be the basis of conviction unless supported by additional strong evidence connecting the accused with the crime. According to the appellant, the prosecution had not established the exact time of death of the victim in a manner that conclusively placed the accused at the scene of the crime at the relevant time. The defence also questioned the reliability of the statements made by witnesses who claimed to have seen the accused and the victim together before the incident. It was argued that these witnesses were either interested parties or individuals whose testimony lacked independent corroboration. The appellant further contended that the prosecution had not established any clear motive for the alleged murder. The absence of motive, according to the defence, weakened the prosecution’s case and created a reasonable doubt about the involvement of the accused. Another significant argument raised by the appellant related to the alleged contradictory statements attributed to him after the incident. The defence argued that such statements could not be treated as conclusive proof of guilt and might simply reflect confusion or panic in a stressful situation. It was also argued that the prosecution had failed to prove conclusively that the towel or dupatta recovered from the room had been used to strangle the victim. The appellant’s counsel also pointed out that the door of the room was found locked from outside when the victim’s son arrived at the scene. According to the defence, this circumstance raised several possibilities regarding the identity of the perpetrator and could not conclusively establish that the accused had committed the crime. The defence further argued that the prosecution had not ruled out the possibility of involvement by another person. Emphasizing the principle that an accused person is entitled to the benefit of doubt, the appellant’s counsel urged the High Court to set aside the conviction and acquit the appellant. It was submitted that the trial court had failed to properly evaluate the evidence and had arrived at its conclusions without adequately considering alternative possibilities that could explain the circumstances surrounding the death of the victim.

Arguments of the Prosecution:

The State of West Bengal strongly defended the judgment of the trial court and argued that the conviction of the appellant was fully justified on the basis of the evidence presented during the trial. The prosecution emphasized that although the case was based on circumstantial evidence, the chain of circumstances established during the investigation and trial was complete and unbroken. According to the prosecution, these circumstances clearly pointed to the guilt of the accused and excluded every other reasonable hypothesis. The prosecution highlighted the fact that the victim had been living exclusively with the appellant in the rented room for several months prior to her death. This circumstance, according to the prosecution, placed the victim under the exclusive custody and control of the accused. In such a situation, the prosecution argued, the burden shifted to the accused to provide a plausible explanation regarding how the victim died while she was in his company. The prosecution further relied on the last seen theory, pointing out that witnesses had seen the appellant and the victim entering the rented room together shortly before the incident. It was also brought on record that the appellant was later seen alone outside the premises early the following morning before he disappeared from the area. According to the prosecution, this sequence of events strongly indicated that the appellant was the last person to be seen with the victim and therefore bore responsibility for explaining the circumstances of her death. Another important aspect emphasized by the prosecution was the suspicious conduct of the accused after the incident. Evidence revealed that the appellant had given contradictory information to different individuals. He told the victim’s son over the phone that she was seriously ill and needed medical attention, prompting the son to rush to the house. However, the appellant reportedly told a co-worker that the victim had died in an accident. According to the prosecution, these inconsistent statements demonstrated the appellant’s nervousness and attempts to mislead others about what had actually happened. The prosecution argued that such conduct was a significant circumstance that pointed towards the guilt of the accused. The medical evidence presented during the trial further strengthened the prosecution’s case. The post-mortem examination revealed that the victim had died due to strangulation, with crushed neck muscles indicating forceful compression of the neck. Blood-stained bedding and clothing recovered from the room indicated that the crime had taken place inside the rented premises where the victim and the accused had been living. The prosecution also referred to the recovery of a gamcha or dupatta from the room, which could have been used as the instrument of strangulation. According to the prosecution, all these circumstances collectively formed a coherent narrative that pointed directly to the involvement of the appellant in the murder of the victim. The prosecution argued that the appellant had failed to provide any credible explanation regarding the circumstances of the victim’s death despite being the person who had been living with her. This failure to explain the circumstances, when combined with the other evidence on record, was sufficient to establish his guilt beyond reasonable doubt. The State therefore urged the High Court to dismiss the appeal and uphold the conviction and life sentence imposed by the trial court.

Court’s Judgment:

After carefully examining the evidence on record and the arguments advanced by both sides, the Calcutta High Court concluded that the trial court had correctly appreciated the evidence and that the conviction of the appellant was justified. The Division Bench observed that although the case was based on circumstantial evidence, the prosecution had successfully established a complete chain of circumstances that pointed exclusively to the guilt of the accused. One of the most important factors considered by the Court was the fact that the victim had been living with the appellant in the rented room for several months before the incident. The Court noted that the victim was under the exclusive custody and control of the appellant during this period. In such circumstances, the appellant had a duty to explain how the victim died while she was in his company. The Court observed that the appellant had failed to provide any plausible explanation regarding the circumstances of her death. The High Court also relied on the last seen theory, noting that witnesses had seen the appellant and the victim entering the rented room together shortly before the incident occurred. The Court further observed that the appellant was later seen alone outside the premises early the next morning and that he subsequently disappeared from the locality. According to the Court, these facts constituted a significant link in the chain of circumstances. The Court also considered the contradictory statements made by the appellant after the incident. The Bench observed that the appellant had informed the victim’s son that she was seriously ill, while telling another person that she had died in an accident. Such inconsistent explanations, the Court held, revealed the nervousness of the accused and constituted a relevant circumstance pointing towards his guilt. The Court noted that a false explanation given by an accused person after the commission of a crime can be treated as an additional link in the chain of circumstantial evidence. The medical evidence presented during the trial also played a crucial role in the Court’s reasoning. The post-mortem report indicated that the victim had died due to strangulation, with crushed neck muscles confirming homicidal death. The presence of blood-stained bedding and clothing in the room further supported the conclusion that the murder had taken place inside the rented premises where the victim and the accused had been staying together. The Court also noted the recovery of a gamcha or dupatta from the room, which could have been used to strangle the victim. Taking all these circumstances into account, the High Court concluded that the prosecution had successfully established an unbroken chain of evidence that led to only one logical conclusion—the guilt of the appellant. The Court therefore held that there was no reason to interfere with the findings of the trial court. Accordingly, the High Court dismissed the appeal and upheld the conviction and life sentence imposed on the appellant. The Court further directed the appellant, who had been released on bail during the pendency of the appeal, to surrender before the trial court within ten days, failing which his bail bonds would stand cancelled. Through this decision, the Calcutta High Court reaffirmed the legal principles governing conviction based on circumstantial evidence and emphasized that when the chain of circumstances is complete and consistent with the guilt of the accused, such evidence can form a reliable basis for conviction in a murder case.