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Sat Parkash v. State of Haryana

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1163 of 2011)Decided 9 Dec 2015
Criminal Appeal No. 1163 of 2011
Justice J.S. Khehar · Justice Rohinton Fali Nariman

Background

Sat Parkash was charged in 1993 with kidnapping a 15-year-old girl, procuring her to be forced into illicit intercourse, rape, and murder (the murder charge was read with the other accused). The girl was found at his home, and she died in a suicide attempt that Sat Parkash also made but survived. The trial court convicted him on several charges, and the High Court upheld the conviction. His uncle and aunt, who were also charged, had already been acquitted, and he had been acquitted of murder.

Decision Breakdown

The Court relied on the girl's suicide note, which said she had left home of her own free will. It held that the presumption that Sat Parkash must have kidnapped her, simply because she was found at his home, was "wholly misconceived". It also held that the evidence did not show she was persuaded or compelled to marry him, and that the procuration charge needed an intent to force or seduce her into intercourse with another person, which was never alleged. Finally, there was no material showing sexual intercourse, so the rape charge could not survive. The convictions were set aside, the appeal was allowed, and his bail bonds were discharged.

Lesson Learnt

A criminal conviction must rest on proof of each legal element of the offence, and a suspicion or presumption is not enough. A written statement by the person concerned, if it is reliable, can be strong evidence against a charge of kidnapping.

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

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