The Supreme Court has acquitted a man convicted in a kidnapping-cum-murder case, holding that the prosecution failed to establish a credible chain of circumstances linking him to either the deceased or the premises where the body was recovered.
A Bench comprising Justice J.B. Pardiwala and Justice K. Vinod Chandran allowed the appeal filed by Kondapaka Sridhar, setting aside the conviction and sentence imposed upon him by the High Court. The judgment was delivered on September 3, 2026, in Kondapaka Sridhar @ Shekar @ Madhu @ Gopi @ Chinna v. State of Telangana.
The Court was particularly critical of the manner in which the investigation had been conducted, observing that the probe had substantially proceeded on the basis of confessional statements rather than independent and legally admissible evidence.
The prosecution case arose after the deceased left his home for Hyderabad and subsequently became unreachable. His father later received a ransom call demanding ₹2 lakh and was instructed to deposit the money into a bank account. He deposited ₹1.5 lakh and thereafter approached the police.
The investigation eventually led the police to an apartment where the deceased’s body was found concealed inside a refrigerator. The prosecution sought to connect Sridhar with the apartment and the crime through a combination of witness testimony, call records, CCTV footage, a test identification parade and the alleged circumstances surrounding the recovery of the body.
The Supreme Court found serious evidentiary deficiencies in the prosecution’s reliance on electronic material.
The CCTV footage relating to withdrawals from an ATM did not establish the identity of the person allegedly making the withdrawals. More importantly, the electronic evidence had not been accompanied by the statutory certification required for its admission in evidence.
Similarly, the prosecution relied upon call detail records to construct a narrative connecting the accused with the other persons involved in the alleged offence. However, the relevant records were not properly proved through the concerned nodal officer and the mandatory certificate concerning electronic records was also absent.
The Court consequently found that the prosecution’s claim of having carefully analysed the call records could not withstand judicial scrutiny.
The Bench also found the identification evidence unreliable.
The prosecution had relied upon a test identification parade to establish the identity of the accused. However, the witness admitted that photographs of the suspects had been shown to him before the identification proceedings were conducted in jail.
The Court considered this circumstance sufficient to undermine the evidentiary value of the identification exercise.
Another critical deficiency concerned the apartment in which the deceased’s body was discovered.
Although the prosecution alleged that the premises had been leased by the accused, it failed to produce the relevant lease document or other satisfactory material establishing his connection with the flat. The ownership and occupancy aspects were also not independently established.
This failure had a direct bearing on the prosecution’s attempt to invoke Section 106 of the Indian Evidence Act, which concerns facts particularly within the knowledge of an accused.
The Supreme Court made it clear that Section 106 cannot be employed as a substitute for the prosecution’s primary obligation to establish the foundational facts of its case. The burden cannot be shifted to an accused merely because the prosecution has failed to first establish a reliable evidentiary link.
The Court observed that the investigation appeared to have been driven primarily by confessions and the narrative that emerged from them, rather than by substantive evidence independently connecting the accused to the offence.
The Bench noted that there was no reliable evidence establishing the appellant’s connection either with the murder or with the apartment where the body was recovered.
In such circumstances, the Court held that the prosecution had failed to complete the chain of circumstances necessary to sustain a conviction in a case resting substantially on circumstantial evidence.
The Court accordingly concluded that there was no legal basis to uphold the High Court’s decision convicting the appellant.
Allowing the criminal appeal, the Supreme Court set aside the High Court’s judgment and the conviction recorded against Sridhar.
The Court directed that he be released forthwith if he remained in custody and was not required in any other case. In case he had already been released on bail, his bail bonds were ordered to stand cancelled.
The judgment reiterates a fundamental principle of criminal jurisprudence: suspicion, even when strong, cannot take the place of proof. Where the prosecution relies upon circumstantial evidence, every incriminating link must be established through legally admissible and reliable material. Investigative lapses, inadmissible electronic records and uncorroborated confessions cannot collectively supply the missing links in the prosecution’s case.
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