Judicial Contradictions And The Fragility Of Circumstantial Evidence — A Case Study Of Ramkirat Munilal Goud V. State Of Maharashtra

“The law is reason free from passion,” said Aristotle—but in the tragic labyrinth of crime and punishment, even reason can be led astray, and passion mistaken for justice. And yet, sometimes, fate intervenes. Not to forgive, not to forget, but to correct.

Prologue to Doom:-

In the shadowy tenements of Thane, Maharashtra, a little girl disappeared. What followed was a tale woven from the fibres of grief, outrage, and flawed deduction. The scene—chaotic. The investigation—hasty. The evidence—circumstantial. And the accused, Ramkirat Munilal Goud, a silent figure in the crowd, found himself cast in the darkest role—the child killer.

The trial court sentenced him to death. The High Court confirmed it. The gallows were prepared. Time, as ever, marched grimly on.

But fate—like literature—loves irony.

The Burden of Presumption:-

In Kafka's “The Trial”, Joseph K. is prosecuted without knowing his crime. Goud knew his charge, but his protest against the system was no less silent. The state, eager to avenge a horror, leaned heavily on what might have been: a blood-stained lungi, muddy shoes, a belated confession, and neighbors who remembered only when asked thrice.

He was seen with the victim. Perhaps.

Her dog was near the scene. Possibly.

He had a scratch. It could mean something.

And that was enough to mark him for death.

The Smile of Fate: Supreme Court Redemption:-

But literature teaches us this: truth has patience. So does justice.

In 2025, the Supreme Court, led by Justice Mehta, laid bare the chasm between suspicion and certainty. The so-called eyewitnesses were found to be unreliable; forensic links, ambiguous; extra-judicial confessions, manufactured. It was a trial wrapped in emotion and executed in haste.

The Court did not deny the horror of the crime. But it refused to substitute vengeance for veracity. With scalpel precision, it excised inference from fact and restored the golden principle: Better that ten guilty escape than one innocent suffer.

The Literary Arc of Redemption:-

This judgment reads not just as legal doctrine but as moral drama. In the theatre of law, where every actor plays to the gallery of conscience, Goud's fate teetered between damnation and deliverance. The apex court, like a merciful chorus in a Greek tragedy, intervened just before the fatal blow.

Not with sentiment, but with structure. Not with mercy, but with method.

Fate's Smile: What Does It Mean?

Fate, in classical literature, is often cruel. But in modern jurisprudence, fate is not divine—it is institutional. When fate smiled on Ramkirat Goud, it did not offer absolution from sin, but protection from the state's own errors.

That smile was a reminder: That in the arc of justice, delay is better than death without proof.

That law must not only act, it must understand.

That in the final court of human dignity, doubt is not a weakness but a shield.

The case of Ramkirat Munilal Goud offers a striking jurisprudential conundrum—how two constitutional courts, analyzing the same body of evidence, reached radically different conclusions. The Bombay High Court affirmed a conviction based on circumstantial evidence and sentenced the appellant to death. In contrast, the Supreme Court of India reversed the judgment, citing serious flaws in the investigation and evidentiary inconsistencies. This case raises critical questions about the judicial treatment of circumstantial evidence, the presumption of innocence, and procedural integrity.

Circumstantial evidence occupies a paradoxical place in criminal law. While capable of forming the basis of conviction, it demands a complete, coherent, and unbroken chain linking the accused to the crime. The case in question lays bare how deviations from these standards can result in judicial divergence.

Factual Matrix and Trial Court Conviction:-

The appellant was accused of abducting, sexually assaulting, and murdering a 3.9-year-old child in Thane. The trial court (Thane) convicted him under Sections 302, 376(2)(i), 363, 201 IPC, and Sections 4 and 8 of the POCSO Act, 2012, awarding the death penalty, citing:

a) "Last seen together" evidence (PW-9, PW-14)

b) Recovery of a blood-stained lungi and muddy shoes allegedly linked to the crime

c) Medical reports indicating injuries consistent with rape

d) Extra-judicial confession to a supervisor (PW-17)

The High Court upheld this conviction, emphasizing the corroborative value of the circumstantial evidence and the reliability of key witnesses.

Supreme Court's Reversal: A Forensic Deconstruction

In a detailed and scathing reversal, the Supreme Court (Mehta, J.) acquitted the accused, underlining:

A. Perfunctory Investigation:-

The Court noted that the first IO (PW-16) did not record timely statements of key witnesses and failed to secure forensic corroboration. The second IO (PW-18) introduced critical statements only after 3rd October 2013, post-arrest, casting doubt on spontaneity and credibility.

B. Unreliable Witness Testimony:-

PW-9 saw the child and accused but made no disclosure until days later.

PW-14 claimed to see the child with the accused but did not inform anyone at the time. The Court labeled these omissions as fatal and contrary to natural human conduct during a community-wide search.

C. Weak Forensic Link:-

No DNA match was established between the accused and the victim.

Blood on the lungi was untraceable to the victim.

Soil on the shoes “resembled” pond soil but lacked exclusivity analysis.

D. Doubtful Extra-Judicial Confession:-

The confession to PW-17 was vague and elicited only during cross-examination, not in chief, and thus deemed manufactured or unreliable.

The Core Contradiction: Same Evidence, Opposite Inference:-

Doctrinal Reflection: Standards in Circumstantial Evidence:-

The case revisits the Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116] test:

1. Circumstances must be fully established.
2. Must be consistent only with the hypothesis of guilt.
3. Must exclude every possible hypothesis of innocence.

The Supreme Court held that these standards were not met, rendering the conviction unsafe.

Implications for Criminal Jurisprudence:-

Danger of Overzealous Prosecution: Courts must be wary of emotional impulse to punish without ensuring factual and legal certainty.

Role of Investigative Gaps: Flaws in initial investigation can irreparably damage prosecutorial legitimacy.

Judicial Responsibility: High Courts must rigorously test the admissibility, spontaneity, and corroborative value of evidence—particularly in capital punishment cases.

Conclusion:-

This case underscores that when liberty and life are at stake, the judiciary must not substitute suspicion for proof. The chasm between the High Court and Supreme Court decisions is not merely legal—it is moral, institutional, and procedural. The case reiterates that even in the face of ghastly crimes, constitutional safeguards and evidentiary discipline cannot be sacrificed.

Epilogue: From the Edge of the Noose:-

Ramkirat Goud did not walk free a hero. He walked free a man saved by the letter of law that had once condemned him. The headlines may forget him, but jurisprudence will not. His case will serve as a parable—for law students, for judges, for citizens—that fate may frown, but it may also smile, provided the courts remember their most sacred duty: not to convict, but to convict justly.

As Camus wrote, “Capital punishment is the most premeditated of murders.” This time, that murder was stayed. Because fate smiled—and justice, finally, saw clearly.

The author is a judicial officer of the rank of Principal District Judge in the State of Maharashtra. He was one of the Additional Directors of the Maharashtra Judicial Academy. Presently, he is the Principal Secretary, Law and Judiciary Department , State of Maharashtra. He can be reached at udaybshukla@gmail.com

Read The Report about the judgment Here | 'Flawed Investigation' : Supreme Court Acquits Death Row Convict In Case Over Rape-Murder Of 3 Year Old Girl

(Justices VIKRAM NATH, SANJAY KAROL AND SANDEEP МЕНТА, JJ.)

Ramkirat Munilal Goud ... Appellant(s);

Versus

State of Maharashtra Etc. ... Respondent(s).

Criminal Appeal No(s). 1954-1955 of 2022

Decided on May 7, 2025