In a recent case in the Bombay High Court, it was held that there is no eye witness and the entire case is based on circumstantial evidence and the Prosecution has to prove all the circumstances beyond reasonable doubt, in a case based on circumstantial evidence.[1] In the given case, the motive was not established by the prosecution. The Court stated as follows:

“There is no evidence whatsoever in support of the charge of conspiracy on the point of meeting of minds of both accused to give effect to their motive. The informant-appellant herein, himself, is unable to assign any reason behind the quarrel. Medical evidence is not sure about death being homicidal, suicidal, or accidental. There is material suggesting other possibilities.”

Earlier, in the case of Kusuma Ankama Rao v. State of Andhra Pradesh[2], it was held as follows:

“The circumstances from which an inference as to the guilt of the accused is drawn have to be proved beyond reasonable doubt and have to be shown to be closely connected with the principal fact sought to be inferred from those circumstances.”

Circumstances, in general, do provide a reason to accuse a person of an offence because sometimes circumstances are such that they seem to create an opportunity for the accused to commit a crime. In these possibilities, it is essential to look at the reasonableness. In case of circumstantial evidence, it is always a rule to establish a chain of events and a proper chain of event will prove the offence of the accused beyond reasonable doubt. In the present case of Salim vs State of Maharashtra & Ors.[3], the only evidence available was circumstantial evidence and if it is the only thing that can be relied upon, then it might as well prove the offence beyond reasonable doubt. If there were eye witnesses or other evidence available, then this circumstantial evidence could have proven itself useful for the purpose of corroboration.