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Jarnail Singh & Anr. vs. State of Punjab

Criminal Appeal · 2022 INSC 708Decided 12 Jul 2022
Criminal Appeal No. 634 of 2010
Ajay Rastogi · Vikram Nath · Hemant Gupta

Background

A driver's 1996 complaint alleged that officials of the Punjab Roadways Depot, Muktsar, were running a ticket-fraud scandal, selling privately printed/reused ("Khaddar") bus tickets and pocketing the proceeds. An inspection committee checked buses and seized old tickets, way-bills and cash, leading to an FIR and prosecution of 15 persons including conductors, inspectors and managers. The trial court and, on appeal, the Punjab and Haryana High Court convicted three bus conductors (Jarnail Singh, Salwant Singh and Balkar Singh) while acquitting the other accused, relying mainly on two witnesses who checked the seized tickets against way-bills, and on the Inspection Committee's enquiry report.

Decision Breakdown

The Supreme Court scrutinised the testimony of the two key prosecution witnesses (PW-8 and PW-15) and found that they admitted, under cross-examination, that they were not present when the tickets were seized, that the tickets were never sealed, and that they could not connect specific tickets to specific buses or conductors. The Court also found that the Inspection Committee's enquiry report was only ever produced as an unproven photocopy. The prosecution had sought permission to lead secondary evidence of the lost original but never actually proved the document's existence or loss as required by law, so the report could not be relied upon at all. With the ticket recovery unconnected to the accused and the enquiry report unproved, the Court held there was no reliable evidence to sustain conviction and acquitted the three conductors.

Lesson Learnt

A criminal conviction cannot rest on documents that were never properly proved (such as an unsealed exhibit or a photocopy substituted for a lost original without actually proving the loss). The prosecution must follow the correct evidentiary procedure for secondary evidence, or the evidence simply cannot be used against the accused.

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

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