MANGI LAL V. STATE OF MAHARASHTRA INSC 230; AIR 1970 SC 1829; 1970 SCR 270; 1969 SCC 731

Issue:

The central issue in Mangi Lal v. State of Maharashtra was whether the accused (Mangi Lal) could be convicted of the murder of a young woman on circumstantial evidence, particularly the reliability of the last-seen theory and the presence of incriminating evidence against him.

Rule:

Last-seen theory: According to this rule, if a person was last seen in the company of the deceased shortly before her death, the onus is on that person to explain how the death occurred or to rebut any inference of guilt that may be drawn from this fact. Circumstantial evidence: For a conviction based solely on circumstantial evidence, the chain of evidence must be so strong and unbroken that it leads to only one conclusion, i.e., the guilt of the accused, without any other possible hypothesis. The legal principles involved included Section 302 of the Indian Penal Code (IPC), which deals with punishment for murder, and Section 106 of the Indian Evidence Act, which places the burden of proof on the accused to explain facts that are specifically within his knowledge.

Application:

In this case, the prosecution relied heavily on circumstantial evidence and the last-seen theory. The victim was last seen alive with Mangi Lal, and her body was found shortly afterward. However, the following points needed to be considered:

Last-seen theory: The court had to determine whether the interval between the time the deceased was last seen with the accused and the time of death was short enough to infer the accused’s involvement. Incriminating evidence: Evidence like bloodstains on Mangi Lal’s clothes and the recovery of the murder weapon from his possession was presented to link him to the crime. Absence of direct evidence: Since there were no eyewitnesses to the crime, the conviction had to rely solely on circumstantial evidence. The court examined whether this evidence formed a complete chain leading to only one conclusion—that Mangi Lal committed the crime. The defense argued that the evidence was insufficient to meet the standards required for a conviction based on circumstantial evidence. They claimed that the prosecution failed to exclude every other hypothesis except the guilt of the accused.

Conclusion:

The Supreme Court upheld Mangi Lal's conviction, stating that the circumstantial evidence and the last-seen theory formed a strong chain of evidence that clearly pointed to his guilt. The court emphasized that although the case relied on circumstantial evidence, it was of such a conclusive nature that no other hypothesis could be derived from it. Therefore, Mangi Lal was found guilty of murder under Section 302 of the IPC.