Prem Singh v. State of Haryana
Background
A young married woman, Sunita, went missing while collecting fodder from her family's fields and was later found dead with a cut throat and signs suggesting a sexual assault had been attempted before the murder. There was no eyewitness to the killing, but the appellant, Prem Singh, who worked in nearby fields and had reportedly been "teasing" and staring inappropriately at the deceased in the days before the murder, was arrested days later. On his disclosure statement, the police recovered gold jewellery belonging to the deceased and the sickle used in the killing, from locations he pointed out. Both the trial court and the High Court convicted him of murder, outraging modesty, and theft, and he appealed to the Supreme Court arguing that the witnesses' testimony was contradictory and the circumstantial evidence was insufficient.
Decision Breakdown
The Supreme Court reviewed the chain of circumstantial evidence: the appellant's prior inappropriate conduct towards the deceased (consistently described by two independent witnesses), his presence near the scene shortly before the murder, the recovery of the murder weapon and the victim's jewellery based on his own disclosure statement, and forensic evidence of semen on the victim's clothing and a bite mark on her cheek. It held that the minor inconsistencies pointed out by the defence between witnesses' court testimony and their earlier police statements were insignificant and did not undermine the otherwise consistent and credible core testimony. The Court agreed with the High Court that these circumstances formed a complete and unbroken chain pointing conclusively to the appellant's guilt, and rejected the argument that mere suspicion was being treated as proof, since here the evidence went well beyond suspicion. Finding the appeal "bereft of any merits," the Supreme Court dismissed it and upheld the conviction and sentence.
Lesson Learnt
In cases built on circumstantial evidence rather than direct eyewitness testimony, a conviction can still stand where the proven facts form a complete and unbroken chain pointing only to the accused's guilt; minor, non-material discrepancies between a witness's police statement and court testimony will not by themselves discredit otherwise consistent and credible evidence.