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Pankaj Singh vs. The State of Haryana

Not available · 2024 INSC 254Decided 21 Mar 2024
Not available

Background

The appellant, a married man, was convicted by the Trial Court under Sections 342 (wrongful confinement), 376 (rape) and 201 (destruction of evidence) of the Indian Penal Code and sentenced to life imprisonment, while being acquitted of other charges including stalking and criminal intimidation. Both the appellant (against conviction) and the prosecutrix, who was also married and 28 years old at the time of the incident (against the acquittal on the other charges), appealed to the High Court, which upheld the Trial Court's judgment in full. The appellant then approached the Supreme Court.

Decision Breakdown

The Supreme Court scrutinised the evidence, including WhatsApp chat messages relied upon by the prosecution, and found that the appellant had never been called upon to admit or deny the genuineness of these chats as required by the Code of Criminal Procedure, and that no certificate under Section 65B of the Evidence Act (required to prove electronic records) had been produced. The Court held that the prosecution's argument that the defect could be overlooked because the documents were undisputed did not hold up in law, since the Court retains discretion to require formal proof. Concluding that the prosecution failed to prove the appellant's guilt beyond reasonable doubt, the Supreme Court quashed the conviction, acquitted the appellant of all charges, and ordered his bail bond cancelled since he was already out on bail.

Lesson Learnt

Electronic evidence like WhatsApp chats cannot be relied upon to convict someone unless it is properly proved, including through a Section 65B certificate under the Evidence Act: a shortcut around this procedural safeguard can be fatal to a criminal conviction.

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

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