The offence of murder is not alien to us, and as such our laws in its form of dynamism have devised means to curb such menace in society. One of these means of getting rid of murder in our society is through the instrumentality of the 'doctrine of last seen'. This presumption of fact known as the doctrine of last seen, which is based on circumstantial evidence, was developed by the Supreme Court. Statutorily, this presumption could be found in section 167 of the Evidence Act.