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Sanjeet Kumar Singh @ Munna Kumar Singh vs State of Chhattisgarh

Criminal Appeal · 2022 INSC 883Decided 30 Aug 2022
Criminal Appeal No. 871 of 2021

Background

The appellant was convicted under Section 20(b)(ii)(C) of the NDPS Act and sentenced to 10 years' rigorous imprisonment after police claimed to have recovered 47.370 kg of ganja from a car he was travelling in with a co-accused, Reena Das. The trial court had acquitted Reena Das because the investigating officer failed to follow proper search procedure against her, even though the same officer's account of the search formed the basis for convicting the appellant. Both independent "panch" witnesses to the search turned hostile at trial, denying they had witnessed anything and explaining they had signed blank documents at the police station for an unrelated reason.

Decision Breakdown

The Supreme Court found serious inconsistencies in the investigating officer's timeline and conduct, including notices allegedly served on witnesses before they could physically have received them, and selective omission of search/seizure formalities for the co-accused Reena Das despite her being named in the original information, FIR and charge-sheet. Since both independent witnesses disowned the search and gave a credible explanation for their signatures, the Court held the very fact of search and seizure was in serious doubt, and therefore the presumption of guilt under Section 54 of the Act (which requires a valid recovery first) could not be invoked. Having already given the co-accused the benefit of this doubt, the Court held the appellant was equally entitled to it, set aside both lower courts' convictions, and ordered his immediate release.

Lesson Learnt

A conviction cannot rest solely on an investigating officer's uncorroborated word when the independent witnesses relied upon deny participating in the search. Courts must scrutinize the actual sequence of events, not just recite the law, especially where the same set of facts led to a co-accused's acquittal.

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

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