The Supreme Court has declined to restore a murder conviction where the prosecution’s circumstantial evidence left material questions unanswered. In State of Himachal Pradesh v. Anchla @ Chanchla, the Court examined the claimed last sighting, a taxi journey, recovered objects, call records, DNA evidence and motive together. It held that the chain did not establish the accused’s guilt beyond reasonable doubt and dismissed the State’s appeal on 1 October 2026.
The official Supreme Court judgment is reported as 2026 INSC 1074, Criminal Appeal No. 166 of 2019. Justices Manoj Misra and Vijay Bishnoi decided the appeal. The ruling is a useful reminder that each proposed link in a circumstantial case must be reliable, and the links, taken together, must exclude a reasonable explanation consistent with innocence.
What was the case about?
In September 2011, police found the bodies of Mithilesh Kumari and her minor son Bhupinder Singh inside their house in Diur, Himachal Pradesh. The autopsy attributed both deaths to strangulation. The prosecution accused Anchla, Mithilesh’s stepdaughter, of killing them. It alleged that Anchla had visited the house on the evening of 31 August 2011, travelled back to Chamba late that night, and had a bleeding injury on her hand. It also relied on keys and Mithilesh’s mobile phone said to have been recovered after Anchla’s disclosure, as well as a DNA match between Anchla’s blood and a stain on a cabinet in the house.
The Sessions Court convicted Anchla under Section 302 of the Indian Penal Code in November 2012. The Himachal Pradesh High Court set aside the conviction in July 2014. The State then appealed to the Supreme Court, asking it to restore the trial court’s decision.
The Supreme Court accepted that the two deaths were homicidal. The question was whether the evidence proved that Anchla was the killer. It examined the prosecution’s proposed chain link by link, including the timing of death, witness reliability, the identification of the lock, the missing mobile location data, the meaning of the DNA result and the alleged property motive.
Why did the “last seen” evidence fail?
The prosecution relied heavily on Mithilesh’s father, who said he saw Anchla at the house on 31 August. The Court found a significant improvement in his testimony compared with his earlier police statement. He had also waited six or seven days before reporting that his daughter and grandson were missing, although he lived nearby and said the house had been locked since the next morning. His explanation for that delay was not tested adequately in the investigation.
Crucially, the medical evidence did not rule out death occurring after the night alleged by the prosecution. A last sighting becomes less decisive when the time of death is uncertain and another person’s involvement cannot be excluded. The Court concluded that it was unsafe to place Anchla at the house on the relevant evening beyond reasonable doubt on this witness’s account alone.
Taxi and hotel witnesses: how did investigators find them?
A taxi driver said he drove Anchla to Diur and back and noticed a thumb injury; a hotel worker said she stayed at a hotel in Chamba that night. Their accounts could have supported the alleged journey. But the investigating officer could not say when he recorded their statements or what led police to those particular witnesses. Anchla’s disclosure did not identify the taxi or hotel. The Court considered that unexplained route to the witnesses important when assessing whether they were natural sources of information or had been introduced to complete a prosecution narrative.
Other details weakened their evidence. The taxi driver did not say he saw Anchla enter the victims’ home or meet either victim. The hotel’s guest record was not produced. The Court did not treat the absence of blood in the taxi, by itself, as enough to reject the driver, but found the broader account untrustworthy. It stressed a straightforward investigative duty: officers collect evidence; they do not create it. On these facts, the driver and hotel worker could not reliably corroborate the disputed last sighting.
What was missing from the call records?
Investigators had obtained call detail records for the deceased and Anchla, but the records lacked corresponding mobile tower locations. The deceased’s phone record was not exhibited in evidence. The Court said location information could have helped test whether the phones were near each other on the critical date, whether Mithilesh’s phone remained active afterward, and whether it moved to Anchla’s residence, where police claimed to recover it.
That missing information mattered because the prosecution placed Anchla with the victims on a particular night. The Court did not say that a tower reading would necessarily prove or disprove presence: a person may leave a phone elsewhere. It found that the unexplained failure to collect and present potentially decisive records seriously weakened this particular account. The alleged recovery of Mithilesh’s phone carried less weight without a complete, exhibited record of its activity and location.
Did the recovered keys connect Anchla to the house?
A forensic test suggested that keys allegedly recovered at Anchla’s instance could operate a lock produced by police. The missing step was proof that this was the same lock actually securing the door when officers found the bodies. Witnesses’ descriptions and identification did not establish that link beyond reasonable doubt. A key fitting a tested lock does not connect a suspect to the crime unless the tested lock is shown to be the relevant one. The Court therefore found the key recovery inconsequential in this evidentiary chain.
Why did the DNA match not prove murder?
The forensic report matched DNA from blood on a cabinet with Anchla’s blood sample. The Supreme Court did not discard that report. It noted questions about why the samples from other places had degraded while those from the cabinet yielded a profile, and the forensic expert was not examined, but accepted the report as it stood. The remaining issue was what the match actually proved.
Anchla had visited the house regularly before the deaths. A trace of her blood on a cabinet could show presence at some point; it did not date that presence to the night of the killings. Her blood was not found on the victims’ clothes or on material alleged to have been used for strangulation. The Court also considered her thumb injury, for which she had given an explanation and produced a hospital slip. With the journey witnesses found unreliable, that injury did little to fix her presence at the crime scene at the prosecution’s chosen time.
The distinction matters beyond this case. A scientific result may reliably identify the source of a trace while leaving the timing, manner of deposit and connection to the charged act unproved. A court still has to assess what inference the result supports in the context of the other evidence.
Motive and the Supreme Court’s decision
The prosecution suggested Anchla wanted to prevent her stepbrother from inheriting her father’s property. No evidence established the claimed bequest. The Court observed that lack of motive is not automatically fatal to a circumstantial case, but becomes significant where the other circumstances are inconclusive. On this record, it found no strong proved motive.
The Court summarised several unresolved gaps: the medical evidence did not fix the deaths to the alleged night; the last-sighting and travel accounts were unreliable; the lock was not adequately identified; the phone recovery and call data were deficient; and the DNA match did not establish when Anchla had been in the house. These were not merely small inconsistencies in an otherwise complete story. The prosecution had neither proved the individual incriminating circumstances to the necessary standard nor connected them into a chain excluding a reasonable innocent explanation.
Accordingly, the Supreme Court found no reason to disturb the High Court’s acquittal and dismissed the State’s appeal. It did not hold that DNA evidence or last-seen testimony can never support conviction. Its decision turned on the specific evidentiary gaps in this prosecution.
For investigators and trial lawyers, the practical lesson is to test each link before treating the whole sequence as complete: establish the relevant time window, document how important witnesses were located, identify recovered objects precisely, preserve and exhibit usable call records, and explain how a forensic match connects a person to the act charged. The official judgment provides the Court’s full reasoning and the underlying evidentiary discussion.
Judgment dated 1 October 2026; reviewed for this update on 6 October 2026 (IST).
