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Writer's pictureAparna Mishra

Is Circumstantial Evidence Enough For A Conviction?



It is said that a person can lie but the circumstances don't. When someone commits a crime, no matter how much he tries he leaves some traces behind him. For example, absence from somewhere, unusual behavior, possession of a weapon, unexplained contact with some people, presence of fingerprint, etc. These actions act as circumstantial evidence in a case.


Evidence is any fact or information which establishes whether a belief is true or false. According to Section 3 of the Evidence Act, 1872 evidence is “all statements which the Court permits or requires to be made before it by witnesses, in relation to matters of fact under inquiry, such statements are called oral evidence”. Evidence may be Direct evidence or circumstantial evidence.

Direct evidence is those evidence that proves a fact or belief without having to infer anything. Such evidence is the most powerful form of evidence. But in cases where direct evidence is insufficient to prove a case, circumstantial evidence or indirect evidence is considered. The judge has to make a decision by reasonable inference from such evidence. Circumstantial evidence plays an important role in deciding a case. Many criminal cases have largely relied on circumstantial evidence in deciding cases. For example, X sees Y coming out of a room with a knife in hand and Z lies dead. Only Y and Z were present in the room. Hence this a circumstantial evidence and not direct evidence as x did not see Y killing Z. The essential components of circumstantial evidence are:

  • Circumstances from which guilt is established are required to be proved.

  • Circumstances should be conclusive in nature and should merely form a link between the criminal and the commission of the offense.

  • Circumstances should retain moral certainty and there should be no scope for any other hypothesis.

  • All other hypotheses should be excluded except that one that is required to be proved.


There are many high-profile cases where circumstantial evidence has been the sole basis of conviction. One of the most recent cases in the State of Kerala v. Sooraj S Kumar (Uthra murder case). In this case, the accused who was the husband murdered his wife by inducing a snake bite upon her. This is one of the rarest cases. In this case, the police submitted about a 2000-page charge sheet connecting the various circumstances related to the murder. They connected the various circumstances related to the murder. Evidence such as his presence in the crime scene, contact with the snake dealer, internet search history, false plea of alibi, no way for the snake to enter the room except the door, etc.

In the case, Jagroop Singh vs. the State of Punjab, the apex court "all circumstances that took place in this case such as the recovery of the weapon which was considered as evidence from the wheat field, convinced them to opine that the prosecution established the chain of circumstances and completed the chain. No trace of doubt could be found and the circumstances of the case were proved beyond a reasonable doubt."

In the case of Manu Sharma v. The State (NCT of Delhi) or popularly known as the 'Jessica Lal Murder Case', High Court observed that the presence of the accused at the crime scene, his conduct after the incident prove his guilt beyond a reasonable doubt.


Citation:


For a more detailed understanding, refer to the" Manu Sharma v. State (NCT of Delhi)" case study by clicking the case below.


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