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"Sri" (Ranjan) v. State rep. by the Inspector of Police, Q Branch, Ramanathapuram

Criminal Appeal · 2026 INSC 516Decided 20 May 2026
Crl.A. No.-005141-005141 - 2025
Justice Vikram Nath · Justice Sandeep Mehta · Justice Vijay Bishnoi

Background

A Sri Lankan national who entered India in 2009 using the name "Ranjan," registered as a refugee, and lived openly in Tamil Nadu for over a decade, was arrested in 2021 on the claim that he was actually "Sri": an absconding accused (A-5) named in a 2015 FIR alleging a conspiracy under the UAPA to supply cyanide capsules and revive the banned LTTE. He was convicted by the trial court and the Madras High Court on charges under Section 120B IPC read with the UAPA, the Poisons Act, the Foreigners Act and the Passport Act, receiving sentences up to five years, based mainly on the testimony of two prosecution witnesses who identified him as "Sri." He maintained throughout that he was never connected to the person named "Sri" in the FIR and had been living under his true identity.

Decision Breakdown

The Supreme Court found the entire case rested solely on belated and unreliable identification testimony from two witnesses who had not named "Ranjan" in earlier proceedings and only did so after his arrest, with no contemporaneous description or independent corroboration linking him to the absconding accused "Sri." The Court noted the appellant had lived openly and registered himself with the police for over a decade, and was actively corresponding with the Swiss Embassy for a visa and seeking a police clearance certificate at the very time he was allegedly absconding: conduct wholly inconsistent with someone evading arrest. Applying settled principles on identification evidence (drawing on its precedent in a similarly-facted mistaken-identity case), the Court held the appellant had been falsely implicated by being assigned another person's identity, set aside both lower court judgments, and acquitted him.

Lesson Learnt

A criminal conviction cannot rest on identification evidence alone when that identification is belated, uncorroborated, and inconsistent with the accused's documented, open conduct during the period he was allegedly absconding. Courts must scrutinise identity evidence with particular care in cases of alleged mistaken identity, especially where the investigating agency made no real effort to locate the actual named suspect.

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

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