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Putai v. The State of Uttar Pradesh

Criminal Appeal · 2025 INSC 1042Decided 26 Aug 2025
Criminal Appeal No(s). 36-37 of 2019, with Criminal Appeal No. 154 of 2025
Justice Vikram Nath · Justice Sanjay Karol · Justice Sandeep Mehta

Background

In September 2012, a 12-year-old girl in a village near Lucknow went missing after going out in the evening and was later found raped and murdered in a field; some of her belongings were found in a field cultivated by one of the two accused. The trial court convicted both accused, sentencing one (Putai) to death and the other (Dileep) to life imprisonment, based on circumstantial evidence including recovered articles, alleged "suspicious conduct," a sniffer dog's identification of one accused's comb, and DNA reports. The Allahabad High Court confirmed the death sentence and dismissed the appeals, leading to this final appeal before the Supreme Court.

Decision Breakdown

The Supreme Court found the investigation and trial riddled with serious flaws: no document proved when or how the accused's blood samples were drawn for DNA testing, breaking the chain of custody; the two medical experts who conducted the post-mortem gave contradictory accounts of how many forensic slides were taken; a "supplementary" DNA report implicating the accused was introduced years later on appeal via affidavit, without recalling the scientist who prepared it for cross-examination, making it inadmissible; and witness testimony about the recovered comb (allegedly identified by a sniffer dog) was inconsistent about even its colour. The Court held the alleged "suspicious conduct" of one accused (washing his face and going home) was entirely natural human behaviour, not incriminating, and that circumstantial evidence must exclude every reasonable hypothesis of innocence, which the prosecution failed to do here. Both accused were acquitted and ordered released.

Lesson Learnt

A conviction, especially a death sentence, built on circumstantial evidence cannot stand if the chain of custody for forensic samples is broken or key scientific evidence is introduced without giving the accused a fair chance to challenge it; courts must scrutinise such gaps rigorously rather than accept a "shabby investigation" at face value.

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

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