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Rajesh & Anr. vs. The State of Madhya Pradesh

Criminal Appeal · 2023 INSC 839Decided 21 Sept 2023
Criminal Appeal Nos. 793-794 of 2022
B.R. Gavai · J.B. Pardiwala · Sanjay Kumar · C.T. Ravikumar

Background

In 2013, a 15-year-old boy, Ajit Pal, went missing and his family began receiving ransom calls demanding money; his body was later found in a well with his throat cut. His neighbour Om Prakash Yadav, along with Yadav's brother Raja Yadav and son Rajesh Yadav, were tried and convicted: Raja Yadav and Rajesh Yadav were sentenced to death for murder and kidnapping-for-ransom, while Om Prakash Yadav received life imprisonment. The Madhya Pradesh High Court confirmed the convictions and death sentences, and the three convicts appealed to the Supreme Court, arguing the case (built entirely on circumstantial evidence, with no eyewitness) was riddled with unexplained gaps and contradictions.

Decision Breakdown

The Supreme Court applied the settled test for circumstantial-evidence cases (that the proved circumstances must form a complete, unbroken chain pointing only to the accused's guilt, excluding every other reasonable hypothesis) and found the prosecution's case fell far short of this standard. It identified numerous serious flaws: conflicting and unexplained accounts of exactly when the boy went missing and when the accused were actually taken into police custody; a discredited "last seen" witness; seizure memos and recovery panchnamas that were mechanically drafted without independent witnesses actually narrating how objects were found; DNA "hair" evidence whose recovery was itself suspect and physically improbable given the accused's and victim's heights; and a complete failure by police to establish that the mobile number allegedly used by Om Prakash Yadav for the ransom calls was actually his, even though the true SIM owner (a different person) was identified but never even questioned. Citing the persistently poor standard of police investigation flagged by the Malimath Committee (2003) and the Law Commission (2012), the Court held that the trial court and High Court had wrongly convicted and even imposed the death penalty despite these "yawning infirmities," and it acquitted all three appellants, giving them the benefit of the doubt and ordering their immediate release (unless held for another case) along with refund of any fines paid.

Lesson Learnt

A conviction, especially one carrying the death penalty, cannot rest on circumstantial evidence riddled with unexplained contradictions, sloppily documented seizures, and unverified forensic links; the law requires the prosecution to close every reasonable gap and exclude every alternative explanation before guilt can be treated as proved beyond reasonable doubt.

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

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