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Darshan Singh v. State of Punjab

Criminal Appeal · 2019 INSC 1327Decided 6 Dec 2019
Criminal Appeal No. 1688 of 2009
Justice L. Nageswara Rao · Justice Hemant Gupta

Background

An elderly woman, Surjit Kaur, was found dead in a field near Morinda, Punjab in March 2005, her body decomposed and her face disfigured with acid, roughly ten days after death. Investigation led to the arrest of her son Avtar Singh, his wife Swaran Kaur, their son Jagmohan Singh, and a servant, Darshan Singh, on the theory that they killed her over a dispute about unpaid lease money for land she had inherited. The trial court acquitted Avtar Singh but convicted Jagmohan Singh, Swaran Kaur, and Darshan Singh, relying heavily on an extra-judicial confession made to a witness (Bhupinder Singh) and corroborating evidence of motive and recovery of physical items; the Punjab and Haryana High Court upheld these convictions, and Darshan Singh and Jagmohan Singh appealed to the Supreme Court (Swaran Kaur having died during the appeal's pendency).

Decision Breakdown

The Supreme Court dismissed both appeals, holding that although the "last seen" witness could not identify the appellants in court, his description of a man and woman disposing of a gunny bag on a motorcycle still fit into the broader chain of circumstances. The Court held that an extra-judicial confession need not always be independently corroborated in every detail, and here it was in fact corroborated: Darshan Singh's confessed role (striking the victim with a chair) matched the postmortem findings of a fractured hyoid bone and rib fractures, and his disclosure led to recovery of the chair itself. The Court also treated the appellants' absence from the village immediately after the killing and from the cremation and prayer ceremony as incriminating conduct, and found the non-payment of lease money (the victim's sole means of survival) established a credible motive. Concluding the prosecution had proved a complete chain of circumstances, the Court upheld the convictions and directed the appellants to surrender to serve their remaining sentences.

Lesson Learnt

A conviction can rest on circumstantial evidence and an extra-judicial confession even without a conclusive "last seen" identification, so long as the confession is corroborated by independent facts (such as medical evidence matching the confessed method of assault) and fits coherently into the overall chain of events, and conduct like avoiding a deceased relative's funeral can itself be treated as incriminating.

Official source (sci.gov.in)View Judgment (PDF)

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