Supreme Court Unravels Flaws in 2004 Murder Conviction: Overturns High Court and Trial Court Verdicts

In a judicial revelation, the Supreme Court meticulously dismantled the conviction in a 2004 murder case, challenging the concurrent findings of both the High Court and the Trial Court. The bench, presided over by Justices B.R. Gavai and P.S. Narasimha, underscored the significance of vigilance when relying on circumstantial evidence, emphasizing that it must align seamlessly with the accused’s guilt hypothesis and remain devoid of doubts, improbabilities, and inconsistencies.

The appeal, filed against the High Court’s judgment, involved an individual accused under Section 302 read with Section 34 of the Indian Penal Code, 1860. The Supreme Court, in its verdict, highlighted a conspicuous “yawning gap” between the charges levied against the appellant and the evidence presented by the prosecution. It asserted that the circumstances failed to establish the appellant’s guilt, deviating from the fundamental principle governing circumstantial evidence.

The case revolved around the murder of the deceased, who was discovered with a knotted throat and a severely injured right eye. The prosecution’s narrative unfolded as the deceased left a shop for the market on his motorcycle, prompting a search by the complainant and other witnesses. The subsequent police investigation led to the trial of the appellant and another accused, with the prosecution presenting 24 witnesses and the defense, three.

The court meticulously scrutinized the trial court’s reliance on circumstantial evidence, expressing dissatisfaction with the High Court’s failure to critically assess the testimony of key witnesses. It deemed the evidence of one witness, PW-10, as unreliable and emphasized the insufficiency of the prosecution’s case. Additionally, the court discredited the FSL report, pointing out inconsistencies in the recovered items and highlighting the absence of independent witnesses during the recovery process.

Referring to its previous decisions and the ‘panchsheel’ of circumstantial evidence, the Supreme Court concluded that the prosecution had not convincingly established its case. Consequently, it overturned the judgments of the High Court and the Trial Court, acquitting the accused of all charges and discharging any existing bail bonds.

The landmark decision in the case of Pradeep Kumar v. State of Haryana marks a pivotal moment where the apex court meticulously dismantled an unsound conviction, emphasizing the necessity for airtight evidence in circumstantial cases.