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Didar Singh @ Dari v. The State of Haryana

Criminal Appeal · 2026 INSC 726Decided 14 Jul 2026
Crl.A. No.-001148-001148 - 2013 (with Crl.A. No. 786 of 2017)
Justice Manoj Misra · Justice Vijay Bishnoi

Background

In 2004, a young man was allegedly taken from his home on a motorcycle by two men (including the appellant) and never returned; his body was found the next morning in a field with head injuries. The trial court convicted both accused of murder based on circumstantial evidence: the "last seen together" theory, a damaged motorcycle linked to one accused, a disclosure statement, and an alleged motive tied to suspected police informing about a drug trade. The Punjab and Haryana High Court upheld the conviction.

Decision Breakdown

The Supreme Court carefully re-examined each circumstance relied upon by the prosecution and found the chain incomplete. The autopsy showed head injuries consistent with a motorcycle accident, the "last seen" evidence was weak and inconsistently reported (the FIR's mention of drag marks was not supported by the site plan), ownership of the motorcycle was never proved beyond doubt, the disclosure statement had no evidentiary value since the location was already known, and the alleged motive was unsupported by any concrete evidence. The Court held that circumstantial evidence must exclude every hypothesis except guilt, and here the evidence actually pointed toward a plausible accident rather than murder. It acquitted the appellants.

Lesson Learnt

A conviction based purely on circumstantial evidence requires an unbroken, fully-established chain that excludes every other reasonable explanation. Courts must scrutinize even "obvious" narratives (like last-seen-together) rigorously rather than accept them at face value, especially when medical and forensic evidence leaves room for an innocent explanation like an accident.

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

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