Murder Conviction Overturned: Supreme Court Acquits Haryana Men Due to Lack of Evidence
The Supreme Court of India has acquitted two men convicted for murder, citing lack of reliable evidence and procedural lapses in the investigation. The case, Randeep Singh @ Rana & Anr. vs. State of Haryana & Ors., revolved around the abduction and brutal killing of Gurpal Singh in 2013. The Court ruled that the prosecution failed to establish the accused’s guilt beyond reasonable doubt.
Background of the Case
The case began with the disappearance of Gurpal Singh on July 8, 2013, from Ambala, Haryana. He was allegedly abducted by a group of men and later found murdered. The prosecution charged eight individuals under Sections 364 (kidnapping), 302 (murder), 201 (causing disappearance of evidence), 212 (harboring offenders), and 120-B (criminal conspiracy) of the Indian Penal Code (IPC).
Key Events
- July 8, 2013: Gurpal Singh was abducted near Prabhu Prem Puram Ashram.
- July 9, 2013: His torso and other body parts were recovered from a canal.
- 2017: The Sessions Court convicted all accused and sentenced them to life imprisonment.
- 2020: The Punjab and Haryana High Court upheld the conviction of the appellants but acquitted the other accused.
- 2024: The Supreme Court overturned the convictions of the remaining two accused.
Arguments Presented
Defense Arguments
Senior Counsel Vinay Navare, representing the appellants, argued:
- The prosecution’s case relied heavily on circumstantial evidence without direct proof.
- The alleged CCTV footage presented by the prosecution was inadmissible as it lacked a valid certificate under Section 65B of the Indian Evidence Act.
- The sole eyewitness (PW-26) had multiple omissions and contradictions in her statements.
- PW-26’s husband, who was reportedly present during the abduction, was not examined by the police.
- Discovery of the vehicle and murder weapon alone was insufficient to convict the accused.
State’s Arguments
The prosecution contended:
- PW-26’s testimony confirmed the abduction of Gurpal Singh.
- CCTV footage showed the presence of the accused at the crime scene.
- Recovery of the murder weapon and the victim’s car linked the accused to the crime.
- The circumstantial evidence was strong enough to establish guilt.
Supreme Court’s Observations
1. Eyewitness Testimony Was Unreliable
- PW-26 did not initially name the accused and only identified them later in court.
- Her police statement lacked key details she mentioned in court.
- Her husband, an alleged eyewitness, was not examined.
2. CCTV Footage Was Inadmissible
- The footage was not certified as per Section 65B of the Evidence Act.
- Neither the bank manager (PW-1) nor the CCTV engineer (PW-24) had verified its authenticity.
- The footage did not bear any identification marks or signatures.
3. Confession to Police Was Illegally Admitted
- The police officer (PW-27) presented statements made by the accused in custody.
- Such confessions are inadmissible under Sections 25 and 26 of the Evidence Act.
- Only confessions made before a magistrate can be considered.
4. Circumstantial Evidence Was Insufficient
- Recovering the victim’s car and a weapon was not enough to prove guilt.
- No forensic evidence linked the recovered weapon to the crime.
- The prosecution failed to establish a complete chain of circumstances.
Key Excerpts from the Judgment
“The brutality of the offence does not dispense with the legal requirement of proof beyond a reasonable doubt. The prosecution has failed to establish the guilt of the accused through admissible evidence.”
“Even if CCTV footage was admissible, neither the trial court nor the High Court actually viewed the footage before relying on it.”
Final Ruling
The Supreme Court ruled:
- The conviction of Randeep Singh @ Rana and Rajesh @ Don was quashed.
- The accused were acquitted and ordered to be released immediately if not required in other cases.
- The ruling of the Punjab and Haryana High Court was overturned.
Implications of the Judgment
1. Strengthening Legal Admissibility Standards
The ruling emphasizes that confessions made to police are inadmissible, and evidence such as CCTV footage must comply with legal standards.
2. Ensuring Fair Trials in Circumstantial Cases
The case highlights that circumstantial evidence alone is not enough unless it forms a complete and unbroken chain proving guilt.
3. Emphasizing the Burden of Proof
The judgment reiterates that in criminal cases, the prosecution must prove guilt beyond a reasonable doubt.
Conclusion
The Supreme Court’s ruling in Randeep Singh @ Rana & Anr. vs. State of Haryana reinforces the importance of due process in criminal trials. By emphasizing the necessity of valid evidence and rejecting unreliable testimonies, the Court upheld the principle that no person should be convicted unless guilt is proven beyond doubt. This judgment serves as a crucial precedent for ensuring fair trials in cases reliant on circumstantial evidence.
Petitioner Name: Randeep Singh @ Rana & Anr..
Respondent Name: State of Haryana & Ors..
Judgment By: Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, Justice Augustine George Masih.
Place Of Incident: Ambala, Haryana.
Judgment Date: 21-11-2024.
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