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LANDMARK CASE

Sharad Birdhichand Sarda v. State of Maharashtra

(1984) 4 SCC 116 · Supreme Court of India · Criminal law

At a glance

  • Citation: (1984) 4 SCC 116
  • Court: Supreme Court of India
  • Area of law: Criminal law
  • In one line: The Court set five 'golden principles': circumstances must be fully established, consistent only with guilt, conclusive, exclude every other hypothesis and form a complete chain.

1 Facts

A husband was convicted of poisoning his wife on circumstantial evidence.

2 Issue

When can a conviction rest on circumstantial evidence alone?

3 What the court decided

The Court set five 'golden principles': circumstances must be fully established, consistent only with guilt, conclusive, exclude every other hypothesis and form a complete chain.

4 Why it matters

These are the standard test for circumstantial evidence.

5 Think about it

Try applying the five principles to a missing link in a hypothetical case.

6 Analyse it yourself

Read the full judgment from an official source or a law database, then brief it in seven steps: facts, issues, arguments, decision, ratio, obiter and significance. Always check the citation before you rely on it.

How to analyse a judgmentHow to cite this case

7 More cases on Criminal law

  • Abhayanand Mishra v. State of Bihar AIR 1961 SC 1698
  • Amish Devgan v. Union of India (2021) 1 SCC 1
  • Bachan Singh v. State of Punjab (1980) 2 SCC 684
  • Balwant Singh v. State of Punjab (1995) 3 SCC 214
  • Barendra Kumar Ghosh v. Emperor AIR 1925 PC 1
  • Basdev v. State of PEPSU AIR 1956 SC 488

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A short teaching summary for students. Educational content only, not legal advice.

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