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Ram Partap vs The State of Haryana

Criminal Appeal · 2022 INSC 1239Decided 1 Dec 2022
Criminal Appeal No. 804 of 2011

Background

The deceased was last seen with the appellant on the day he died; the appellant later brought the deceased's dead body to the family's house in a jeep and told the deceased's brother that the deceased had died at the appellant's own house. Based mainly on this, and the brother's complaint, an FIR was registered, and the appellant was tried and convicted of murder, with the High Court upholding his conviction while acquitting other co-accused and setting aside a related conspiracy charge against him.

Decision Breakdown

The Supreme Court acquitted the appellant, holding that the case rested entirely on circumstantial evidence that failed the settled test requiring every link in the chain to be proved beyond reasonable doubt and to exclude every hypothesis except guilt. It found the key witness's account of the appellant's confession absent from his original oral complaint, an unexplained 14-hour delay in reporting the incident to police, and the sole "last seen" witness turning hostile. Since the trial court had already disbelieved the very same witnesses' evidence in acquitting the other accused (an acquittal the High Court upheld), there was no proper basis left to sustain the appellant's conviction either.

Lesson Learnt

A conviction cannot rest on suspicion, however strong. Where a case depends entirely on circumstantial evidence, every circumstance must be proved and must together form a complete, unbroken chain pointing exclusively to the accused's guilt, with no gap left to be filled by conjecture.

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

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