Darshan Singh vs. State of Punjab
Citation: 2024 INSC 19; Bench: Justice B.R. Gavai, Justice P.S. Narasimha, Justice Aravind Kumar
Background
This case revolved around the alleged murder of Amrik Kaur, the wife of Darshan Singh (appellant), amid a strained marital relationship attributed to Darshan Singh’s long-standing extramarital affair with Rani Kaur. The prosecution contended that on the night of May 18–19, 1999, Darshan Singh and Rani Kaur administered poison to Amrik Kaur, resulting in her death. Both were charged under Section 302 read with Section 34 IPC (murder with common intention). The trial court convicted both, sentencing them to life imprisonment. On appeal, the High Court acquitted Rani Kaur but upheld Darshan Singh’s conviction. Darshan Singh then appealed to the Supreme Court.
Supreme Court’s Analysis
Evidentiary Gaps and Contradictions:
The Supreme Court scrutinized the prosecution’s evidence and found significant omissions and contradictions in witness testimonies and the chain of circumstances. The Court observed that the circumstantial evidence presented failed to establish a complete and unbroken chain pointing only to the guilt of Darshan Singh, as required in cases based on circumstantial evidence.
Section 313 CrPC Statement:
The Court reiterated that a statement recorded under Section 313 of the Code of Criminal Procedure (CrPC) cannot be the sole basis for conviction. Conviction must rest on substantive, corroborated evidence, not merely on the accused’s procedural statements or omissions during examination.
Selective Acquittal and Benefit of Doubt:
The acquittal of Rani Kaur by the High Court, while upholding Darshan Singh’s conviction on the same set of evidence, was found to undermine the consistency and coherence of the prosecution’s case. The Court emphasized that when two accused are tried on identical evidence, selective acquittal without clear justification casts doubt on the reliability of the prosecution’s version.
Presumption of Innocence and Fair Trial:
The Supreme Court underscored the fundamental principles of criminal law—presumption of innocence, the necessity for a robust and complete chain of evidence in circumstantial cases, and the right to equitable treatment of co-accused.
Decision
The Supreme Court allowed Darshan Singh’s appeal and set aside his conviction and sentence. The Court held that the prosecution’s case did not meet the requisite standard of proof beyond reasonable doubt, and the benefit of doubt must go to the accused.
Significance
This judgment reaffirms the judiciary’s commitment to fair trial standards, strict adherence to evidentiary requirements in criminal cases, and the principle that conviction cannot rest on procedural statements or incomplete circumstantial evidence. It highlights the need for consistent treatment of co-accused and robust judicial scrutiny in criminal appeals.
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