Protecting Justice through Evidentiary Standards

Facts of the Case

1. Nature of the Crime: The appellants were accused of kidnapping and murdering Gurpal Singh on July 8, 2013. His mutilated body was found the next day.
2. Trial Court Judgment: The Sessions Court convicted the appellants under Sections 364, 302, 120-B, and 201 of the Indian Penal Code (IPC), sentencing them to life imprisonment.
3. High Court Appeal: The High Court upheld the appellants’ convictions but acquitted other accused individuals.

Contentions of the Parties

Appellants (Randeep Singh and Co-Accused):

1. The prosecution relied on flawed evidence, including inadmissible CCTV footage without the requisite Section 65B certificate under the Indian Evidence Act.
2. Eyewitness testimony (PW-26) was unreliable due to major omissions and lack of prior identification.
3. There was no legally sufficient evidence connecting them to the crime beyond circumstantial recovery of the car and weapon.

Respondent (State of Haryana):

1. Argued that eyewitness testimony (PW-26) and circumstantial evidence, including CCTV footage, established the appellants’ guilt.
2. Highlighted the brutality of the crime, insisting it warranted severe punishment.

Principles Enunciated

1. Admissibility of Evidence: The Court emphasized strict adherence to evidentiary rules, notably the requirement for a Section 65B certificate for electronic evidence.
2. Reliability of Eyewitness Testimony: Eyewitness testimony lacking corroboration or proper identification cannot be the sole basis for conviction.
3. Circumstantial Evidence: The Court reiterated that the chain of circumstantial evidence must be complete and rule out all other hypotheses but the accused’s guilt.
4. Confessions to Police: Statements made in police custody are inadmissible except as provided under Section 27 of the Indian Evidence Act (limited to recovery-related disclosures).

Final Order

The Supreme Court allowed the appeal, acquitting the appellants due to insufficient legal evidence to prove their guilt beyond a reasonable doubt. The prior convictions were quashed, and the appellants were ordered to be released immediately unless required in connection with any other cases.

Impact on Public Law and Order

This judgment underscores the paramount importance of adhering to procedural fairness and evidentiary standards in criminal trials. By highlighting flaws in reliance on inadmissible evidence, it safeguards against wrongful convictions and reinforces the integrity of the justice system, promoting public trust.

Citation: Randeep Singh @ Rana & Anr. vs. State of Haryana & Ors., 2024 INSC 887.