DATE: 04/04/2025
COURT: Supreme Court of India
BENCH: Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta
FACTS:
In June 2016, a minor girl went missing during a Jagran (religious function) held in her village. Her father lodged an FIR and continued searching for her when he was informed that a young girl's body had been found in a nearby field. He, along with his family, rushed to the spot and identified the deceased as his daughter. Suspecting sexual assault followed by murder, the body was sent for post-mortem, which confirmed multiple injuries on her head and private parts. The accused was later apprehended, and it was alleged that he confessed before a Magistrate at the behest of the Investigating Officer.
The accused was tried before the Fast Track Court/Special POCSO Judge and was convicted under relevant provisions of the IPC and POCSO Act. The Trial Court awarded him the death sentence and referred the matter to the Uttarakhand High Court under Section 366 CrPC for confirmation. The accused also filed an appeal challenging the conviction. The High Court dismissed the appeal and upheld the death sentence, which was then challenged before the Supreme Court in the present appeals.
ISSUES:
The main issues in this case were on the order of the Trial Court dated 5th April, 2017 and the order passed by the High Court reaffirming the findings and inference of the Trial Court. The issue were whether these judgements were accurate in convicting the appellant.
JUDGEMENT WITH REASONING:
The Supreme Court set aside the conviction of the appellant, quashing the judgments delivered by the Trial Court (dated 5th and 6th April 2017) and the Uttarakhand High Court (dated 5th January 2018). The Court acquitted the appellant of all charges and ordered his immediate release from custody, provided he is not required in any other case. The appeals were allowed, and all pending applications were disposed of accordingly.
The Supreme Court found glaring procedural and evidentiary lapses in the prosecution’s case, ultimately concluding that the trial was conducted in a highly irregular and legally unsustainable manner. One of the Court’s primary concerns was the improper reliance on the DNA evidence. It observed that the DNA expert, who had conducted the forensic analysis, was never examined during trial. Instead, the DNA report was introduced into evidence merely through the Investigating Officer (PW-14), who had no direct involvement in preparing the report. The Court reiterated that such reports cannot be admitted automatically under Section 293 of the CrPC without proper authentication through expert testimony. Furthermore, the prosecution failed to prove critical steps in the chain of custody, such as proper sealing of the samples, storage procedures, and safe transmission to the Forensic Science Laboratory (FSL). No forwarding letter was exhibited, and no witness from the FSL or the police malkhana (storage facility) was examined to confirm the integrity of the samples.
The Court also took serious note of the trial court’s flawed approach in allowing a police officer to narrate the appellant’s alleged confession verbatim during examination-in-chief, which is in clear violation of Sections 24, 25, and 26 of the Indian Evidence Act. This improper admission of a confessional statement further undermined the fairness of the trial. The cumulative effect of these procedural irregularities, lack of credible forensic linkage, and violation of evidentiary norms led the Court to conclude that the conviction could not be sustained. In the absence of legally admissible and trustworthy evidence, the appellant's guilt could not be established beyond reasonable doubt.
ANALYSIS:
The Supreme Court’s judgment in this case underscores the critical importance of adhering to due process and evidentiary standards in criminal trials, especially those involving serious charges like rape and murder. The Court emphasized that procedural lapses—such as failing to examine the DNA expert, not proving the chain of custody for forensic samples, and allowing inadmissible confessional statements—seriously compromised the integrity of the trial. It highlighted that the trial court’s acceptance of a police officer's narration of the accused's confession was a direct violation of the Indian Evidence Act, which prohibits the use of such confessions unless they meet strict legal safeguards. This procedural misstep, coupled with unproven DNA reports and undocumented evidence handling, cast significant doubt on the reliability of the prosecution's case.
By acquitting the appellant, the Supreme Court reaffirmed the principle that criminal convictions must be based on evidence that is both legally admissible and convincingly credible. The judgment reflects a strict scrutiny of forensic and testimonial evidence, reiterating that legal shortcuts or procedural negligence cannot justify a conviction, regardless of the seriousness of the allegations. It sends a strong message to lower courts and law enforcement agencies about the necessity of upholding constitutional protections and evidentiary rigor to ensure a fair trial. In doing so, the Court not only corrected a miscarriage of justice but also reinforced foundational principles of criminal jurisprudence in India.
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