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Ravi v. The State of Punjab

Criminal Appeal · 2025 INSC 170Decided 10 Feb 2025
Crl.A. No.-000633-000633 - 2025 (arising from SLP (Crl) No. 7712 of 2022)
Justice Pankaj Mithal · Justice Ahsanuddin Amanullah

Background

The appellant was convicted by the trial court and the Punjab and Haryana High Court for murdering his first wife, who was found dead with ligature marks on her neck. The prosecution's case rested entirely on circumstantial evidence, including a Zero FIR lodged by the deceased's brother naming the appellant, and the testimony of the deceased's sister who lived nearby and was described as having seen the incident. However, both these key witnesses turned hostile at trial: the brother testified he had signed a blank paper and that his sister actually died of illness, and the sister likewise stated there was no dispute between the couple and that the death was due to illness.

Decision Breakdown

The Supreme Court found that with both principal prosecution witnesses turning hostile and disowning their earlier statements, the chain of circumstantial evidence collapsed. It also faulted the lower courts for ignoring the appellant's statement under Section 313 CrPC that his wife had died a natural death from chronic tuberculosis, noting the prosecution failed to get the post-mortem doctor re-examined or produce independent medical evidence to rebut this explanation. Since the evidence permitted two equally plausible conclusions, the Court held the benefit of doubt had to go to the appellant, set aside the High Court's judgment, and ordered his immediate release after over ten years in custody.

Lesson Learnt

A criminal conviction cannot stand on circumstantial evidence where the key witnesses turn hostile and an innocent explanation offered by the accused is never seriously investigated or rebutted by the prosecution. Courts must give the accused the benefit of doubt when the evidence reasonably supports two competing conclusions.

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

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