Darshan Singh vs The State of Punjab
Background
The appellant's wife died of aluminium phosphide (a pesticide) poisoning in 1999. The prosecution alleged the appellant and a woman he was allegedly having an affair with jointly administered the poison to eliminate the wife, motivated by their illicit relationship. The Trial Court convicted both the appellant and the co-accused woman of murder. On appeal, the High Court upheld the appellant's conviction but acquitted the co-accused woman, giving her the benefit of the doubt on the ground that her presence at the scene that night was not adequately proved by the evidence.
Decision Breakdown
The Supreme Court found this outcome internally inconsistent: since the same witnesses (the victim's sister and brother-in-law) were relied upon to prove both the appellant's and the co-accused's presence at the house that night, and their testimony was riddled with omissions and contradictions on cross-examination, it could not be said to reliably prove the appellant's presence while being too weak to prove the co-accused's. Because proof of presence was essential to trigger the reverse burden under Section 106 of the Evidence Act, and because the evidence also cast doubt on whether the poison (which has a strong, hard-to-miss garlic-like smell) could have been secretly administered, the Court held the prosecution had failed to establish an unbroken chain of circumstances. It set aside the conviction and acquitted the appellant.
Lesson Learnt
In a case resting entirely on circumstantial evidence, courts cannot accept the same testimony as sufficient to convict one accused while rejecting it as insufficient to convict a co-accused for the identical fact (presence at the scene). If the evidence is too weak for one, it is too weak for both, and any real gap in the chain of circumstances entitles the accused to the benefit of the doubt.