Supreme Court Upholds Acquittal of Woman Accused of Killing Stepmother, Stepbrother

The Supreme Court recently dismissed the Himachal Pradesh government's appeal against the acquittal of a woman accused of murdering her stepmother and stepbrother, holding that the circumstantial evidence did not form a complete chain excluding reasonable hypotheses consistent with her innocence.

A Bench of Justices Manoj Misra and Vijay Bishnoi upheld the Himachal Pradesh High Court's decision to acquit Anchla alias Chanchla in the 2011 double-murder case, finding that the prosecution had failed to establish several crucial circumstances beyond reasonable doubt.

Court questioned the credibility of two witnesses who allegedly linked Anchla to the crime, observing that their statements appeared to have been recorded to create evidence. It also flagged the failure to collect mobile phone tower-location data as a serious investigative lapse and held that the DNA match relied upon by the prosecution did not conclusively establish her guilt.

"Neither the incriminating circumstances were proved beyond reasonable doubt nor they constituted a chain so far complete as to exclude all hypothesis consistent with the innocence of the accused," Justice Misra, who authored the judgment, observed.

Background

The case arose after the bodies of Mithilesh Kumari, Anchla's stepmother, and her minor son Bhupinder Singh were discovered at their residence in Diur on September 7, 2011.

Mithilesh's father, Bhagi Ram, had informed the police that his daughter had been missing for six to seven days and that her house was locked. After entering the house, police found both bodies. Post-mortem examinations established that the deaths were homicidal and caused by strangulation.

The prosecution alleged that Anchla, who was the daughter of Mithilesh's husband Amar Singh from his first marriage, had murdered the two to secure property allegedly bequeathed by her father to Bhupinder.

The prosecution relied on the testimony of Bhagi Ram, who claimed that Anchla was present at Mithilesh's house on the evening of August 31, 2011, and that Mithilesh had told him she would be staying overnight with her. The prosecution also relied on a taxi driver's account of Anchla's alleged journey between Chamba and Diur that evening and her subsequent stay at a hotel in Chamba.

Other circumstances included an injury to Anchla's left thumb, the recovery of a bunch of keys and Mithilesh's mobile phone allegedly at her instance, and a forensic report matching her DNA profile with blood collected from an article inside the house.

The trial court convicted Anchla under Section 302 of the Indian Penal Code (corresponding to Section 103 of the Bharatiya Nyaya Sanhita) in November 2012. However, the Himachal Pradesh High Court set aside the conviction in July 2014, holding that the prosecution had failed to prove the charge beyond reasonable doubt. The State challenged that acquittal before the Supreme Court.

Circumstantial evidence must exclude reasonable hypotheses of innocence

Examining the State's appeal, the Supreme Court said an appellate court should not interfere with an order of acquittal if the view taken by the trial court is a possible view, unless the judgment is perverse, ignores relevant evidence or is based on unsustainable grounds.

Court emphasised that the presumption of innocence is strengthened by an acquittal and that interference is warranted only where there are substantial and compelling reasons to prevent a miscarriage of justice.

After examining the incriminating circumstances, the Bench noted that although the deaths of the two victims were homicidal, it was not proved beyond doubt that they occurred in the intervening night of August 31, 2011 and September 1, 2011. The possibility that the deaths occurred later was not ruled out by the medical evidence.

Court also held that the accused's presence in the deceased's house was not proved beyond reasonable doubt. The complainant, who was relied upon as a witness to the last-seen circumstance, had made an improvement over his earlier statement and was not wholly reliable. The other witnesses were also not credible enough to corroborate the last-seen circumstance.

Why did Court doubt the recovery and DNA evidence?

The Bench noted that the recovery of the keys to the lock and the deceased's mobile phone at the instance of the accused did not inspire confidence, particularly because of an investigative lapse in obtaining the Call Detail Records (CDR) along with the tower location of the mobile phone.

The CDR of the deceased's mobile phone was also not exhibited before the Court.

Court further held that the DNA match between the profile generated from the accused's blood and the profile generated from a blood-stained scrape collected from a cabinet in the deceased's room was not conclusive of her involvement.

The Bench noted that the accused was a regular visitor to the house and, therefore, the possibility that the blood had been present there from an earlier occasion could not be ruled out.

"Importantly, blood of the accused was not found present on the clothes of the deceased woman and her son or on the cloth with which they were allegedly strangulated," the Bench said.

Court also pointed out that the suppression of the deceased's mobile CDR and its tower location created an impression that the prosecution was withholding vital information. The data could have helped determine whether the deceased died on the date and at the time alleged by the prosecution or later, and whether the accused and the deceased were at the same place at any point in time, Court noted.

"Failure to collect and exhibit technical evidence like CDRs with tower locations of mobile phones, particularly when the prosecution relies on the proximity of the accused and deceased, constitutes a serious investigational lapse. Such omissions create gaps in the evidence that undermine the reliability of the prosecution's timeline and the last-seen theory," the Bench said.

Lapses in investigation

The prosecution had relied on taxi driver Vijay and hotel worker Suresh Kumar to corroborate Anchla's alleged presence in Diur on August 31 and her return to Chamba after midnight. Court discarded their testimonies as well, noting that the investigating officer had failed to explain how or why those witnesses were contacted.

"While an investigating officer has the duty to collect evidence, the sudden appearance of witnesses whose knowledge of the crime is otherwise unexplained raises suspicion that they have been set up to create evidence. The failure of an investigating officer to provide a logical basis for identifying such witnesses may justify considering them unreliable," the Bench said.

In conclusion, Court held that neither the incriminating circumstances had been proved beyond reasonable doubt nor did they form a chain complete enough to exclude all hypotheses consistent with the accused's innocence.

Finding no reason to interfere with the high court's decision, the Bench said, "We have no hesitation in holding that the prosecution had failed to bring home the charge against the accused".

Case Title: State of Himachal Pradesh Vs Anchla @ Chanchla

Bench: Justices Manoj Misra and Vijay Bishnoi 

Date of Judgment: October 01, 2026