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Tarun Sharma vs. State of Haryana

Not available · 2025 INSC 1139Decided 1 Sept 2025
Not available
Justice Vikram Nath · Justice Sandeep Mehta

Background

The appellant was convicted of murder and sentenced to life imprisonment by the trial court, a conviction later upheld by the Punjab and Haryana High Court. The prosecution's case rested mainly on a statement/dying declaration allegedly recorded from the injured victim before he died, and on the recovery of a knife following the appellant's disclosure statement. The appellant challenged the conviction before the Supreme Court, arguing that the dying declaration and recovery evidence were unreliable.

Decision Breakdown

The Supreme Court found serious infirmities in how the statement/dying declaration was recorded. The prosecution could not prove it was faithfully recorded or that it was an unimpeachable document, and its contents contradicted the ocular (eyewitness) testimony. On the recovered knife, the Court noted the forensic science laboratory report did not establish any blood group on the weapon and no serological report linked the blood on it to the deceased, making the recovery evidentially inconsequential, reiterating that mere recovery of a weapon cannot by itself prove guilt. With both pillars of the prosecution's case undermined, the Court held that guilt had not been established beyond reasonable doubt, set aside the High Court and trial court judgments, and acquitted the appellant, ordering his immediate release.

Lesson Learnt

A criminal conviction cannot stand on a dying declaration or weapon recovery that is not scientifically and procedurally corroborated; courts must scrutinize such evidence rigorously, and the benefit of any genuine doubt goes to the accused.

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

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