Insufficient Evidence and Circumstantial Doubts Lead to Declaration of Acquittal of Accused: Supreme Court
Case Title: Pradeep Kumar v. State of Haryana
Case No: Criminal Appeal No. 1338 of 2010
Decided on: 5th January, 2024
CORAM: THE HON’BLE MR. JUSTICE B.R. GAVAI AND HON’BLE MR. JUSTICE P.S. NARASIMHA
Facts of the Case
In the present case, according to the Prosecution’s account, the deceased left his shop on a motorcycle to go to a market. When the deceased failed to return home that night, his wife informed the complainant. Seeking information about the deceased’s whereabouts, the complainant, accompanied by another prosecution witness, initiated a search. During the search, the complainant received information about a discovered dead body. Subsequently, the complainant and other prosecution witnesses reached the location and found the deceased with his throat bound by a piece of cloth. The complainant promptly reported the incident to the police, leading to the registration of an FIR. The Trial Court convicted the Appellant under Section 302 read with Section 34 of the Indian Penal Code, 1860 (IPC), sentencing them to life imprisonment for the murder of the deceased. Dissatisfied with this verdict, the Appellant appealed to the High Court of Punjab & Haryana, which upheld the conviction and sentence. Subsequently, the Appellant sought relief from the Supreme Court, challenging the decision of the High Court.
Issue
Whether the High Court’s ruling justified in the case of an individual accused under Section 302 of the Indian Penal Code, 1860?
Legal Provision
Section 302 of the Indian Penal Code, 1860 states that whoever commits murder shall be punished with death or imprisonment for life, and shall also be liable to fine.
Court’s analysis and decision
The court observed a substantial disparity between the allegations against the Appellant and the evidence presented by the prosecution. The circumstances outlined failed to establish the guilt of the Appellant; instead, they raised doubts, improbabilities, and inconsistencies. Emphasizing the need for caution when dealing with cases reliant on circumstantial evidence, the Supreme Court underscored the importance of careful scrutiny. Consequently, the Court acquitted the accused of all charges, leading to the allowance of the appeal.
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Written by- Afshan Ahmad