Table of Contents
Case Title
Anand Jakkappa Pujari @ Gaddadar v. State of Karnataka (with connected case)
Citation: 2026 | Supreme Court of India
Introduction
The Supreme Court examined the evidentiary value of the “last seen together” theory in a criminal trial based on circumstantial evidence. The Court held that this circumstance is relevant but cannot form the sole basis of conviction. Courts must look for strong corroborative evidence that completes the chain of circumstances.
Factual Background
The prosecution relied on the testimony of PW-7. The witness stated that he saw the deceased travelling in a Maruti 800 car near Mudhol at about 5:30 PM. He further stated that the accused joined the vehicle at that time.
After a few days, the deceased went missing. The authorities later recovered her dead body.
The witness informed the family members after a delay of several days. The police recorded his statement after about 10–12 days.
During cross-examination, the witness admitted that he had close relations with the family of the deceased. He also admitted that he did not inform the police or the family immediately.
These facts created serious doubt about the credibility of the witness.
The prosecution argued that the accused were last seen with the deceased and, therefore, they were responsible for the crime
Supreme Court Held
Conviction for a serious offence like murder cannot be based solely on the last seen theory, as such reliance is legally unsafe.
The “last seen together” theory applies only when the time gap between the accused and the deceased being seen together and the death is very small, leaving no scope for third-party intervention.
Courts must require additional corroborative evidence that directly connects the accused with the crime.
The last seen circumstance is only one link in the chain of circumstantial evidence and cannot by itself establish guilt.
Where a significant time gap exists or supporting evidence is absent, reliance on the last seen theory becomes unsafe.
Delay in disclosure by a key witness reduces credibility and weakens the prosecution case.
Even if the Court accepts that the accused were last seen with the deceased, absence of other incriminating evidence makes conviction unsustainable.
Case Laws Discussed
State of U.P. v. Satish (2005) 3 SCC 114
The Supreme Court held that the last seen theory becomes relevant only when the time gap is very small. The Court also held that conviction based solely on this circumstance, without corroboration, is hazardous.
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