Rajbir Singh vs The State of Punjab
Background
The appellant, a neighbourhood dairy farmer, was convicted of murdering a neighbour's wife by allegedly mixing poison in milk supplied to the family, motivated by a dispute over an unpaid loan of Rs. 1 lakh he had allegedly borrowed from the deceased's husband. The Sessions Court convicted him under Section 302 IPC, and the Punjab and Haryana High Court upheld the conviction. He appealed to the Supreme Court, challenging the reliability of the circumstantial and forensic evidence against him.
Decision Breakdown
The Supreme Court closely re-examined the chain of circumstantial evidence required for a poisoning conviction (motive, cause of death by poison, possession of poison, and opportunity to administer it) and found serious gaps. The alleged loan and pronote evidencing motive were not proved, since the original documents were never produced and no attesting witness was called. There was a long, unaccounted-for gap of over 24 hours between when the milk was collected and when samples were seized, during which tampering could not be ruled out. Critically, the doctor who conducted the autopsy found none of the physical symptoms typically associated with organophosphorus poisoning, and the chemical examiner's reports bore suspicious overwriting and were received from a suspended official in an "opened," not sealed, condition, raising real doubts about sample integrity. Concluding that the prosecution had failed to prove guilt beyond reasonable doubt, the Court gave the appellant the benefit of the doubt, acquitted him, set aside both lower court judgments, and discharged his bail bond.
Lesson Learnt
A conviction in a circumstantial-evidence case, especially one resting on forensic samples, cannot stand if there are unexplained gaps in the chain of custody or inconsistencies between medical findings and the alleged cause of death; the prosecution must close every reasonable loophole, not just build a plausible theory.