Stringent Standards in Circumstantial Evidence Cases and the Need for a Conclusive Chain of Evidence to Establish Guilt: Supreme Court

The recent judgment of the Supreme Court of India [Pradeep Kumar Vs. State of Haryana], involves the conviction of Pradeep Kumar, the sole appellant, for the murder of a person. The trial court found Pradeep Kumar guilty under Section 302 read with Section 34 of the Indian Penal Code, sentencing him to rigorous imprisonment for life. The High Court of Punjab & Haryana upheld the conviction, leading to the appeal in the Supreme Court.


The prosecution’s case rested on circumstantial evidence, primarily the statements of witnesses PW-10, PW-11, and PW-12, along with some recoveries and a confession. The witnesses claimed to have seen the accused with the deceased on the night of the murder. Additionally, an extra-judicial confession was allegedly made before the Ex-Sarpanch (PW-10). The High Court affirmed the conviction, relying on the evidence of PW-11 and PW-12, despite expressing reservations about the reliability of PW-10.


However, the Supreme Court carefully scrutinized the evidence and found serious discrepancies and inconsistencies. The judgment highlighted the unreliability of the witnesses, pointing out contradictions in their statements. PW-10, the Ex-Sarpanch, claimed the accused confessed to him on 17.04.2004, but the accused stated they were arrested on 11.04.2004. This discrepancy raised doubts about the truthfulness of the extra-judicial confession.


The Court criticized PW-11, a chance witness, for providing inconsistent details about the events on the night of the murder. The witness, who claimed to have seen the accused with dandas, recorded the motorcycle’s registration number during the incident. However, the Court found it implausible that the witness, engaged in changing a car tire at night, could have made such observations with precision.


Similarly, PW-12, another chance witness, claimed to have seen the accused with dandas near the crime scene. The Court questioned the probability of his account, emphasizing the simultaneous actions of urinating, coughing, and recording the registration number.


The judgment also highlighted the lack of recovery of a sharp-edged weapon, inconsistent descriptions of the recovered pant, and issues with the blood group match. The prosecution failed to establish a consistent chain of evidence that conclusively proved the guilt of the accused.


In conclusion, the Supreme Court found that the prosecution had not met the standard of proof beyond a reasonable doubt. Due to the unreliability and inconsistencies in the evidence, the Court acquitted Pradeep Kumar of all charges and set aside the convictions. The judgment emphasized the importance of stringent standards in circumstantial evidence cases and the need for a conclusive chain of evidence to establish guilt.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. The content may not reflect the most current legal developments and is not guaranteed to be accurate, complete, or up-to-date. Readers should consult a qualified legal professional before taking any action based on the information provided. The authors and publishers disclaim any liability for any loss or damage incurred as a result of reliance on this article. This article does not create an attorney-client relationship.

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