The last-seen-together theory
The prosecution relied on a claim that the deceased was last seen with an accused. The Court found no proof of the deceased being seen with the accused immediately before death. The time of death was not established with precision. The medical estimate allowed a range of possible times. That uncertainty weakened the inference sought from the last-seen circumstance. Earlier association with the deceased is not enough by itself. The circumstance must be proved and fit with the other established evidence. The last-seen theory was not proved in this case. (Bernard Lyngdoh Phawa v. The State of Meghalaya | 2026 INSC 85)