Wahid v. State Govt. of NCT of Delhi

Criminal Appeal · 2025 INSC 145Decided 4 Feb 2025
Crl.A. No.-000201-000201 - 2020 (heard together with Criminal Appeal No. 202 of 2020, Anshu v. State Govt. of NCT of Delhi)
Justice Pamidighantam Sri Narasimha · Justice Manoj Misra

Background

Late at night in December 2011, four men boarded a mini-bus (Gramin Sewa) in Delhi and, at knife- and pistol-point, robbed the driver, conductor and passengers of their mobile phones and cash before fleeing. Two of the accused, Wahid and Anshu, were convicted by the trial court under Sections 392/397 IPC (robbery with a deadly weapon), with Anshu also convicted under the Arms Act, and their convictions were upheld by the Delhi High Court. They appealed to the Supreme Court, arguing that the manner of their arrest and identification was unreliable.

Decision Breakdown

The Supreme Court found serious inconsistencies in the prosecution's account of how and when the accused were arrested, including a key witness's cross-examination testimony suggesting he had not actually seen the accused at the time of arrest and had signed blank papers at the investigating officer's request. Because the arrest itself was doubtful, the recovery of the alleged weapons (screwdriver, knives, pistol) at the time of that arrest was also rendered unreliable, particularly since such items are not unique. On identification, out of seven eyewitnesses only three identified the accused in court, three others affirmatively said the accused were not the robbers, no test identification parade was ever held, and the courtroom "dock identifications" occurred years after the incident: none of which inspired confidence. Given the combined doubts about arrest, recovery, and identification, the Court held the appellants were entitled to the benefit of the doubt, set aside the High Court's judgment, and acquitted them.

Lesson Learnt

A criminal conviction cannot stand on doubtful arrest circumstances and unreliable, uncorroborated eyewitness identification, especially where no test identification parade was conducted and courtroom identification came years after the alleged crime: the benefit of the doubt must go to the accused when the prosecution's evidentiary chain has serious gaps.

Criminal LawSupreme Court of India

Charming Rupon v. State of Meghalaya

The Supreme Court acquitted the accused, finding the prosecution's case riddled with serious doubt. Both the victim and her cousin (a key witness) admitted in cross-examination that they could not identify the accused and that his name had been supplied to them by the victim's mother, raising a strong suspicion of tutoring, especially since the victim admitted she had been coached by the public prosecutor before testifying. The mother's own conduct (not reacting urgently despite being told of the assault, and material facts missing from the belated FIR) was found "unnatural." A crucial witness, the school teacher whose disclosure triggered the FIR, was never examined, without explanation, warranting an adverse inference against the prosecution. The Court also noted that two medical witnesses were never meaningfully cross-examined because the defence counsel was absent on the relevant dates, and that the trial court had wrongly brushed aside credible alibi evidence led by the accused.

Decided 9 Oct 2026Read case
Criminal LawSupreme Court of India

Ramkrushna Prahllad Dongardive v. The State of Maharashtra

The Supreme Court restored the trial court's acquittal. It found that the prosecution never produced the original cashbooks, daily registers, or audit reports that would have actually proven the appellant was entrusted with and misappropriated the money: the investigating officer himself admitted these documents were never shown to him despite being asked for. The department also failed to produce records the appellant had specifically sought in his own defence. Separately, the search and seizure of documents from the appellant's house was legally doubtful, since both independent witnesses to the seizure turned hostile and denied knowing its contents, and the mandatory procedural safeguards for such a seizure were not followed. The Court also flagged that the High Court convicted the appellant for the very first time on appeal without ever hearing him on the question of sentence, which the law required it to do.

Decided 8 Oct 2026Read case
Criminal LawDelhi High Court

Gurpreet Singh vs. State (NCT of Delhi)

The Court accepted that the order recalling the proclaimed offender status be placed on record. Noting that the complainant was untraceable and the prosecution itself raised no serious objection to anticipatory bail, the Court found no reason to deny the applicant liberty. It granted anticipatory bail, directing release on a personal bond of Rs. 20,000 with one surety in the event of arrest.

Decided 7 Oct 2026Read case
Criminal LawDelhi High Court

Mukesh Rani vs. Narcotics Control Bureau

The Court noted the investigation was complete, the chargesheet was filed, the co-accused had already been granted bail, and the combined quantity recovered (1.976 kg) still fell short of the "commercial quantity" threshold under the NDPS Act. With ten witnesses yet to be examined and no indication the trial would conclude quickly, the Court found continued detention unnecessary and granted regular bail on a personal bond of Rs. 50,000 with standard conditions.

Decided 7 Oct 2026Read case
Criminal LawDelhi High Court

Aakash vs. State Govt. of NCT of Delhi and Anr.

The Court noted that all prosecution witnesses, including the complainant and the guest house manager, had already been examined, and that a co-accused in the same FIR had already been granted bail. Given the complainant's own testimony about voluntary association with the petitioner and the completed trial evidence, the Court found the overall facts favoured bail. It granted regular bail on a personal bond of Rs. 50,000 with standard conditions (reporting to police weekly, not influencing witnesses, providing address/mobile details).

Decided 7 Oct 2026Read case
Criminal LawDelhi High Court

Kundan Kumar vs. State NCT of Delhi & Anr.

The Court relied on earlier Delhi High Court rulings holding that whether a broken promise of marriage was "false" from the outset (criminal) or a mere "breach" (not criminal) is a question for trial, not something requiring custodial interrogation. Noting the investigation was complete and the applicant had no prior criminal record, the Court granted regular bail on a personal bond of Rs. 25,000 with conditions, clarifying the order was not an opinion on the merits.

Decided 7 Oct 2026Read case