State of Himachal Pradesh v. Anchla @ Chanchla
Supreme Court of India | Criminal Appeal No. 166 of 2019 | Judgment dated 1 October 2026
1. Introduction
The Supreme Court has dismissed an appeal by the State against the acquittal of Anchla @ Chanchla, who was convicted by the Trial Court for the murder of her stepmother, Mithilesh Kumari, and stepbrother, Bhupinder Singh, but later acquitted by the Himachal Pradesh High Court.
The Supreme Court held that although the deaths were undoubtedly homicidal, the prosecution failed to establish the complete chain of circumstances necessary to prove that Anchla was the perpetrator.
What makes this judgment particularly interesting is the fact that while the prosecution provided several seemingly incriminating circumstances, including last-seen evidence, a thumb injury, keys and mobile phone recovery, DNA matching and an alleged motive, the Court found that the circumstances, singly or jointly, did not reach the level of proof beyond reasonable doubt.
The judgment is particularly interesting because of what it teaches about the law of circumstantial evidence.
The judgment's central principle can be summarized as follows:
Suspicion that is supported by several incriminating circumstances may not substitute a complete and conclusive chain of circumstantial evidence.
2. Facts of the Case
Mithilesh Kumari was the second wife of Amar Singh. Anchla belonged to his first marriage. Mithilesh Kumari and her minor son Bhupinder Singh lodged at Diur.
Anchla allegedly visited Mithilesh Kumari's house on 31 August 2011. According to the prosecution, she would stay there till the evening and travel back towards Chamba.
The house was found locked the following day. Mithilesh Kumari and Bhupinder Singh did not come out, and their bodies were eventually found on 7 September 2011 after foul odour emanating from the house prompted the police to intervene.
Post-mortem examination established that the deceased had died from homicidal deaths caused by strangulation.
The prosecution suspected that Anchla had killed them to get hold of property bequeathed by her father to Bhupinder Singh.
The Trial Court convicted her under Section 302 IPC, based primarily on a chain of circumstantial evidence.
The Himachal Pradesh High Court found serious flaws in the prosecution's evidence and acquitted her.
The State came before the Supreme Court.
3. Prosecution's Case
The prosecution mainly relied on the following circumstances:
1. Anchla was present in the house of Mithilesh Kumari on 31 August 2011.2. The house was found locked after that.3. The mobile phone of the deceased was off.4. The bodies were found many days later.5. Anchla travelled by taxi from Chamba to Diur and returned at night.6. She had a bleeding injury to her thumb.7. Her fingers were treated on 1 September 2011.8. Keys that could open the lock of the house of the deceased were recovered upon her disclosure.9. The mobile of the deceased was recovered from Anchla's house.10. Blood found matched Anchla's DNA.11. The prosecution alleged that she had a motive since her father had given property to Bhupinder Singh.
The Trial Court found these circumstances sufficient to prove the guilt of the accused.
4. Defence Case
The accused denied all incriminating circumstances.
Her explanation for the thumb injury was that she got it injured while going to Mani Mahesh and her thumb was crushed between the door of a car. She had herself produced the medical slip that explained the treatment.
The defence challenged:
• last-seen;• taxi driver;• the alleged hotel stay;• the key recovery;• the mobile recovery;• the DNA evidence;• the failure of the prosecution to produce complete CDR and tower location information; and• the motive of Anchla.
The defence argued that the prosecution had not succeeded in elevating its case from suspicion to proof.
5. Issue Before the Supreme Court
The primary issue was:
Whether the evidence relied upon by the prosecution was a complete and conclusive chain of circumstances proving, beyond reasonable doubt, that Anchla had committed the murders as to justify interference with the acquittal order by the Himachal Pradesh High Court?
6. Scope of Appeal Against Acquittal
Before moving on to a detailed examination of the evidence, it may be useful to recall a principle relating to appeals against acquittals.
An acquittal promotes the presumption of innocence. Thus, while an appellate court possesses the power to re- appreciate evidence, it ordinarily should not interfere with the view taken by the acquitting court if it is a reasonably possible view.
Interference becomes justified only when the judgment is perverse, palpably erroneous, unreasonable or based on the rejection of cogent evidence.
The Court relied on several precedents including:
• State of Rajasthan v. Shera Ram @ Vishnu Dutta, (2012) 1 SCC 602;
State of M.P. v. Bacchudas @ Balram, (2007) 9 SCC 135; and
Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471.
Thus the Supreme Court entered into the appeal with the caution commensurate with an appeal against acquittal.
7. Law Relating to Circumstantial Evidence
The prosecution's case was entirely based on circumstantial evidence.
The Supreme Court reiterated that the law requires that every incriminating circumstance first be established independently.
The circumstances must then form a chain which:
• is complete;• is consistent only with the guilt of the accused;• excludes reasonable hypotheses that are consistent with innocence; and• conclusively points towards the accused as the perpetrator.The Court referred to Hanumant v. State of Madhya Pradesh and Sharad Birdhichand Sarda v. State of Maharashtra as authority for this principle.
This principle becomes crucial in this case.
8. Last-Seen Evidence - The First Major Weakness
The prosecution relied extensively on PW-1, who claimed to have seen Anchla at the house of the deceased.
However, the Supreme Court found an important gap in his evidence.
His earlier statement under Section 161 CrPC did not mention that he saw Anchla talking to Bhupinder Singh.
It thus treated his deposition as an improvement over the previous statement.
The Court held that it would be unsafe to rely on his testimony to show that Anchla was present with the deceased at the relevant time.
More importantly, it said that the medical evidence did not conclusively prove that the murders took place during the intervening night of 31 August and 1 September.
Since the post-mortem indicated that the deaths may have occurred anywhere between 5-7 days before, it was possible that they occurred later.
This was a major blow to the prosecution's last-seen theory.
9. Taxi Driver and Hotel Witness - Evidence Found Untrustworthy
PW-4, the taxi driver, claimed that Anchla had travelled from Chamba to Diur and subsequently returned to Chamba.
PW-18, a hotel worker, allegedly supported the claim that Anchla had stayed at a hotel.
However, the Supreme Court found several problems with this evidence.
The investigating officer did not explain:
• When the statements of PW-4 and PW- 18 were recorded; and
• What prompted the investigating agency to approach these witnesses.
The Court considered this to be important in determining whether these witnesses were natural witnesses or had been designed to construct a chain of circumstances.
The Court ultimately concluded that PW-4 and PW-18 were not trustworthy enough to corroborate the last-seen circumstance.
The failure to produce hotel records further hurt PW-18's evidence.
10. A Significant Observation on Investigation
One of the most important observations in this judgment relates to the difference between collecting and creating evidence.
The Supreme Court emphasized that the job of an investigating officer is to collect evidence relevant to the offence.
When a witness has no apparent reason to approach the police and the investigator cannot explain why that witness was brought in, the circumstances surrounding the recording of the statement become relevant to determining its credibility.
The Court found it particularly significant that the investigating officer could not explain the recording of the statements of PW-4 and PW-18.
It therefore concluded that they appeared to have been recorded to create a chain of evidence rather than as a natural consequence of the investigation.
11. Failure to Collect Tower Location - A Serious Investigational Lapse
This is one of the significant aspects of the judgment.
The police had got the CDRs of the deceased and the accused, but they did not contain the tower location information.
The Supreme Court held that this information would have been useful in establishing:
• whether the accused's mobile was close to the location where the bodies were found;
• whether the deceased's mobile was in operation after 31 August;
• whether it received calls after that date;
and where the mobile was located.
The Court described this failure to collect this information as a serious investigational lapse.
It also noted that the CDR of the deceased's mobile was not even exhibited.
This was particularly important since the prosecution's case was heavily based on the fact of the accused and deceased being together at the relevant time.
12. Recovery of Keys - Chain Not Established
The prosecution relied on the recovery of keys that allegedly could open the lock found on the house of the deceased.
But the Court found a crucial gap in this evidence.
The prosecution had to establish:
1. that the house was locked;
2. that the lock actually seized by the police was the one used to secure the house; and
3. that the keys recovered from the accused operated that lock.
The evidence failed to establish this chain.
PW-3 saw the lock on the handle of the door, not the one securing the latch.
PW-15, who witnessed the breaking of the lock, did not identify the lock produced before the Court as the one present.
The investigating officer himself was not present when the lock was broken.
Consequently, the Court found that the alleged recovery of keys was rendered inconsequential.
13. Recovery of Deceased's Mobile - Serious Doubts
The alleged recovery of Mithilesh Kumari's mobile phone from the house of the accused was also examined closely.
The Supreme Court found several problems with this evidence:
• CDR of the mobile was not exhibited;
• no evidence established whether it was switched off;
• no evidence showed whether it received calls after 31 August;
• no tower location information;
and no reason was given why the accused would carry the deceased's mobile to her house.
The Court observed that it was possible that the mobile phone was removed from the crime scene and planted elsewhere, making the evidence of complete CDR and tower location particularly important for corroboration.
Accordingly, the alleged recovery did not have sufficient incriminating value.
14. DNA Evidence - Matching Does Not Automatically Prove Murder
Perhaps the most legally significant aspect of this evidence relates to DNA.
The prosecution established that DNA obtained from the accused's blood matched blood found on the material collected from a cabinet/trunk at the scene.
The Supreme Court did not reject the report outright.
It accepted it as it was, but examined what it actually proved.
The Court reasoned that the match only proved that the accused's blood had been present at the location at some point in time.
The match did not prove that:
• she was present there on 31 August 2011;
the blood was deposited during the murders; or
she was the person that committed the murders.
This was particularly important since the prosecution itself admitted that Anchla often visited the house of the deceased.
Moreover, her blood was not found on the clothes of the deceased or on the material that allegedly strangled them.
Thus:
DNA presence ≠ proof of presence at the relevant time ≠ proof of participation in the crime.
15. Thumb Injury - Suspicious but Not Conclusive
The accused undoubtedly had an injury to her thumb and obtained treatment on 1 September 2011.
The prosecution tried to connect it to the alleged bleeding injury seen by PW-4 on her return journey.
But after rejecting the credibility of PW-4, the prosecution lost the primary evidentiary link in this case.
The accused had even produced the medical slip explaining the injury.
The Court therefore concluded that the presence of the injury was proved, but its incriminating value was not.
16. Motive - Alleged Property Dispute Not Established
The prosecution alleged that Anchla murdered her stepmother and stepbrother because her father had bequeathed his property to Bhupinder Singh.
But there was no evidence of the bequest.
The Court further noted that Amar Singh had five daughters from his first wife, including Anchla. Therefore unless Bhupinder Singh was excluded entirely as a beneficiary, the accused would not necessarily be the sole beneficiary.
Consequently, the property motive was not proved.
The Court reiterated that absence of motive is not a fatal blow to prosecution. However, in the case where the rest of the circumstantial evidence is inconclusive, absence of a convincing motive becomes of great significance.
17. Chain of Circumstances Remained Incomplete
Having examined each of the major circumstances separately, the Court brought them together.
It found that:
• the time of death was uncertain;
• the presence of the accused at the house on the relevant date was not established beyond reasonable doubt;
• last-seen evidence was unreliable;
• taxi and hotel witness did not offer reliable corroboration;
• identity of lock was not established;
• recovery of keys therefore lost significance;
• recovery of mobile was doubtful;
• CDR and tower location evidence was inadequately investigated;
• DNA evidence established no more than the presence of the accused's blood at some point;
the thumb injury did not conclusively connect her with the murders; and
the alleged motive was not proved.
The Court therefore concluded that the prosecution's case failed to establish a chain of circumstances that excluded reasonable hypothesis consistent with innocence.
18. Final Holding
The Supreme Court held that the prosecution had failed to bring home the charge against the accused.
Since the acquittal by the High Court was a reasonably possible view of the evidence, there was no justification for interference with the acquittal.
The State's appeal was therefore dismissed.
The judgment was delivered by Justice Manoj Misra and Justice Vijay Bishnoi on 1 October 2026.
19. Ratio Decidendi
The main legal propositions emerging out of this judgment can be summarized as:
A. Circumstantial evidence must form a complete chain
Each incriminating circumstance must be independently established and the circumstances collectively must exclude reasonable hypotheses consistent with innocence.
B. Last-seen evidence cannot operate in isolation where the time of death is uncertain
Where medical evidence leaves open a substantial possibility that death occurred later, the last-seen circumstance loses much of its connecting force.
C. DNA evidence must be assessed in its factual context
A DNA match demonstrating the presence of blood of the accused at the location does not, by itself establish when the blood came there or that the accused participated in the offence.
D. Recovery evidence requires foundational facts
Recovery of keys is of little value unless the prosecution first proves that the recovered keys operated the very lock securing the crime scene.
E. Electronic evidence can be crucial corroboration
Where the prosecution relies upon mobile-phone movements to establish presence or sequence of events, failure to collect relevant tower-location data may constitute a serious investigational lapse.
F. An appeal against acquittal requires judicial restraint
Where the High Court's view is reasonably possible on the evidence, the Supreme Court ordinarily will not substitute another view merely because it could have reached a different conclusion.
20. Humanistic and Justice-Oriented Analysis
This judgment reminds us of the fine balance between suspicion and proof that is at the heart of criminal adjudication.
There were two deceased persons and a serious allegation of double murder, making the demand for accountability understandable.
Yet the criminal justice system cannot rely on suspicions raised by troubling circumstances alone, simply because the alternative is to let the killer go free.
The Supreme Court's approach in this case demonstrates that the seriousness of an offence does not reduce the prosecution's evidentiary burden.
At the same time, this judgment exposes the consequences of investigative deficiencies.
The questions concerning tower locations, timing of witness statements, lock identity, complete CDRs and the preservation and interpretation of forensic evidence were capable of materially affecting the reconstruction of events.
The case thus demonstrates an important principle of criminal justice:
The prosecution must prove not merely that the accused appears connected with the circumstances, but that the evidence forms a logically complete chain leading to guilt and excluding reasonable innocence.
An acquittal in such circumstances is not a declaration that the crime did not occur. The Supreme Court expressly accepted that the two deaths were homicidal. The issue was whether the State had proved, with the required degree of certainty, who committed them.
21. Key Takeaway for Legal Practitioners
The present judgment is particularly instructive when dealing with cases founded upon circumstantial evidence.
A prosecution cannot successfully construct a chain merely by accumulating several suspicious circumstances. Every link must be legally proved, factually connected and collectively capable of excluding reasonable alternatives.
In this case, the prosecution had several apparently incriminating pieces of evidence - but the Court found that the links connecting those pieces to the accused and to the precise time of the murders were insufficient.
The case thus reinforces the distinction between:
"There are reasons to suspect the accused"
and
"The evidence proves beyond reasonable doubt that the accused committed the offence."
In criminal law, that distinction is fundamental.
Conclusion
The Supreme Court's decision in State of Himachal Pradesh v. Anchla @ Chanchla is a strong reaffirmation of the rule that circumstantial evidence must form a complete and conclusive chain before it can sustain a conviction.
The judgment is equally important for its treatment of DNA evidence, mobile-phone CDRs and tower locations, recovery evidence, investigative methodology, witness credibility and appeals against acquittal.
Ultimately, the Court found that the prosecution's case remained at the level of suspicion because several essential links were either unreliable, unproved or incapable of conclusively connecting the accused with the murders.
The State's appeal was accordingly dismissed and the acquittal was allowed to stand.