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Criminal LawSupreme Court of India

Pradeep Kumar vs. State of Haryana

Not available · 2024 INSC 21Decided 5 Jan 2024
Not available
Justice B.R. Gavai · Justice Pamidighantam Sri Narasimha

Background

The appellant and a co-accused were convicted of murdering one Shamsher Singh in 2004 and sentenced to life imprisonment, a conviction upheld by the Punjab & Haryana High Court. There were no eyewitnesses; the case rested entirely on circumstantial evidence: an alleged extra-judicial confession made to a former village Sarpanch, and the testimony of two "chance witnesses" who claimed to have seen the accused near the crime scene on the night in question, plus forensic blood-group matches on recovered clothing and a stick.

Decision Breakdown

The Supreme Court closely scrutinised each strand of circumstantial evidence and found all of it unreliable. The Sarpanch's extra-judicial confession story was undermined by contradictions and by a co-accused's own statement indicating the accused had already been arrested days before the supposed confession. The two "chance witnesses" told highly improbable stories: one claimed to notice a bloodstain and painstakingly memorise a motorcycle number plate at night on a dark road while changing a car tyre, and could not explain a multi-hour gap in his own timeline; the other, only educated to class six, claimed to memorise a number plate from a distance while relieving himself in the dark. Applying the settled "five golden principles" for circumstantial evidence cases (from Sharad Birdhichand Sarda), the Court held that suspicion, however strong, cannot substitute for proof beyond reasonable doubt, and that the chain of circumstances here was neither complete nor conclusive. The appellant was acquitted of all charges.

Lesson Learnt

A conviction based purely on circumstantial evidence must form an unbroken chain pointing only to guilt, with every other explanation excluded: implausible "coincidence" witness accounts and unexplained gaps in a story are enough, by themselves, to defeat a prosecution case, however serious the underlying crime.

Pradeep Kumar vs. State of Haryana – Legal Case Shots | LegalAware