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Pulkit @ Monu v. The State of Madhya Pradesh

Criminal Appeal · 2026 INSC 543Decided 20 May 2026
Crl.A. No.-001818-001818 - 2022
Justice Manoj Misra · Justice Manmohan

Background

Four persons, including the appellant Pulkit @ Monu, were tried for the murder of one Ashok Bakdiya in 2008. While three co-accused were convicted for the murder itself, the appellant was separately convicted for criminal conspiracy to commit murder under Section 302/120B IPC, based on circumstantial evidence such as an alleged pre-incident meeting, overheard remarks, a disclosure statement, an old dispute with the deceased, and a mobile phone call made after the crime. Both the trial court and the High Court of Madhya Pradesh upheld his conviction, even after discarding the testimony of two key prosecution witnesses whose statements were found to have been recorded after illegal detention.

Decision Breakdown

The Supreme Court re-examined each circumstance relied upon by the lower courts and found them individually weak and, taken together, insufficient to form a complete chain pointing conclusively to the appellant's guilt. It held that the disclosure statement did not lead to any fresh "discovery of fact" admissible under the Evidence Act, that the seized mobile phone and its call records lacked proper certification and probative value, and that mere prior friction with the deceased did not establish a conspiracy beyond reasonable doubt. Concluding that the circumstances did not rule out every other reasonable hypothesis except guilt, the Court set aside the conviction, allowed the appeal, and acquitted the appellant.

Lesson Learnt

A conviction for criminal conspiracy cannot rest on a patchwork of ambiguous or weakly-linked circumstances: every link in the chain of circumstantial evidence must be proved beyond reasonable doubt and must exclude every reasonable hypothesis other than the accused's guilt.

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

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