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Harjindra Singh Etc. v. The State of U.P.

Criminal Appeal · 2026 INSC 569Decided 27 May 2026
Crl.A. No.-002811-002812 - 2024
Justice Pankaj Mithal · Justice Prasanna B. Varale · Justice Aravind Kumar

Background

An 8-year-old boy, Satnam Singh, was abducted at pistol point on his way to school in 2003 by men on a motorcycle; a ransom demand of Rs. 5 lakh was allegedly made to his family. The child was recovered a few days later based on a disclosure by one of the accused, and a firearm was recovered based on another accused's disclosure. The trial court convicted the appellants under Section 364A (kidnapping for ransom) and related provisions, and the Allahabad High Court upheld the conviction; the appellants then appealed to the Supreme Court, arguing the case rested on interested witnesses, lacked a formal identification parade, and left the ransom-call evidence uncorroborated.

Decision Breakdown

The Supreme Court held that the ransom demand was proved through consistent oral testimony of family members and the investigating officer, and that the absence of a call-detail record from a rural 2003-era telephone exchange could not undermine otherwise credible oral evidence. It rejected the argument that the lack of a Test Identification Parade was fatal, noting a TIP is only corroborative and unnecessary where witnesses had a clear, sustained opportunity to observe the accused and later identified them in court. The Court further found the appellants' identities were "decisively cemented" by recoveries made under Section 27 of the Evidence Act, the child was recovered on one accused's disclosure and the crime weapon on the other's, which the Court treated as strong independent proof of guilt. It also dismissed the defence's reliance on the victim's family visiting one appellant in jail as evidence of false implication, accepting the plausible explanation that they went to identify the real mastermind.

Lesson Learnt

A conviction can stand firmly on corroborated oral testimony and recoveries made under Section 27 of the Evidence Act even without a formal identification parade or documentary call records. Courts look at the totality and credibility of evidence rather than insisting on any one specific procedural safeguard.

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

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