The Supreme Court of India overturned the life imprisonment conviction of the appellants for a brutal murder, citing a lack of legally admissible evidence and flaws in the prosecution's case. The case involved charges under Sections 364, 302, 201, 212, and 120-B of the IPC. The court emphasized the inadmissibility of confessions to police, procedural lapses in handling evidence, and the importance of proving guilt beyond a reasonable doubt. It reiterated that brutality cannot override the legal principle of proof.

1. Facts of the Case (Para1–2)

   • Gurpal Singh was abducted and brutally murdered on July 8, 2013, with his dismembered body found the following day.
   • Accused, including Randeep Singh, were convicted for offenses under IPC Sections 364, 302, 120-B, and 201 by the Sessions Court, with sentences upheld by the High Court.

2. Prosecution's Evidence (Para3–8)

   • Relied on eyewitness testimony (PW-26), CCTV footage from a nearby bank, and recovery of a weapon and the deceased’s vehicle.
   • Significant omissions in PW-26’s testimony were found, and no test identification parade was conducted.
   • Husband of PW-26, an alleged eyewitness, was not examined, raising an adverse inference against the prosecution.

3. Inadmissible Evidence: Confessions and CCTV Footage (Para9–12)

   • CCTV footage lacked a Section 65B certificate under the Evidence Act and was deemed inadmissible.
   • PW-1 (Bank Manager) and PW-24 (CCTV Engineer) failed to verify the integrity of the footage.
   • Police-used confession statements of the accused were inadmissible under Sections 25–27 of the Evidence Act.

4. Circumstantial Evidence (Para12–13)

   • Prosecution’s reliance on circumstantial evidence did not meet the five-principle test laid down in Sharad Birdhichand Sarda vs. State of Maharashtra.
   • The discovery of the deceased’s body and related items lacked a direct link to the accused.

5. Judicial Oversight (Para14–16)

   • The trial and High Court relied on inadmissible evidence, including police confessions and unverified CCTV footage.
   • Section 27 exceptions were misapplied, incorporating inadmissible statements.

6. Judgment and Acquittal (Para17–18)

   • The Supreme Court quashed all convictions, ruling that the prosecution failed to establish guilt beyond reasonable doubt based on legally admissible evidence.

Acts and Sections Discussed:

1. Indian Penal Code (IPC):

   • Section 364: Kidnapping for murder
   • Section 302: Murder
   • Section 201: Causing disappearance of evidence
   • Section 212: Harboring offender
   • Section 120-B: Criminal conspiracy

2. Indian Evidence Act, 1872:

   • Sections 25–27: Admissibility of confessions and discoveries
   • Section 65B: Admissibility of electronic evidence

3. Code of Criminal Procedure, 1973:

   • Section 161: Statements to police

Ratio Decidendi:

1. Admissibility of Evidence:

   • Confessions to police are inadmissible unless they lead to a discovery under Section 27 of the Evidence Act.
   • In the absence of a Section 65B certificate, electronic evidence like CCTV footage is inadmissible.

2. Eyewitness Credibility:

   • Significant omissions and lack of corroborative identification undermine the reliability of eyewitness testimony.

3. Circumstantial Evidence:

   • Failure to satisfy the five-principle test for circumstantial evidence invalidates the prosecution’s case.

4. Burden of Proof:

   • Even in brutal offenses, moral conviction cannot substitute for proof beyond reasonable doubt.

Subjects: 

Criminal Law, Evidence Law, Murder Trial, Admissibility of Evidence
Murder Acquittal, Indian Penal Code, Evidence Act, Circumstantial Evidence, Procedural Lapse