In a significant judgment, the Supreme Court of India, led by Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, and Justice Augustine George Masih, acquitted the appellants Randeep Singh @ Rana and Rajesh @ Don in the high-profile Gurpal Singh murder case. The case, which revolved around allegations of abduction and murder under Sections 364, 302, 201, 212, and 120-B of the IPC, highlighted critical legal issues surrounding the admissibility of evidence and the standards required for conviction.
Case Background
The case originated in July 2013 when Gurpal Singh, father of complainant Jagpreet Singh, was allegedly abducted near Prabhu Prem Puram Ashram and later found brutally murdered. His torso and other body parts were recovered from a canal on July 9, 2013. Eight individuals, including the appellants, were convicted by the Sessions Court in Ambala and sentenced to life imprisonment. However, while the High Court of Punjab and Haryana acquitted other co-accused, the convictions of the appellants were upheld, leading to the present appeal.
Key Legal Issues
1. Reliability of Eyewitness Testimony
– The prosecution relied heavily on the testimony of Paramjeet Kaur (PW-26), sister of the deceased, who claimed to have witnessed the abduction. However, significant omissions in her police statements and the absence of a test identification parade raised questions about her reliability.
– The court held that these omissions amounted to contradictions, rendering her testimony inadmissible.
2. Admissibility of CCTV Footage
– The prosecution presented CCTV footage purportedly showing the involvement of the accused. However, the absence of a certificate under Section 65B of the Indian Evidence Act and inconsistencies in the chain of custody led to its rejection as evidence.
3. Confessional Statements to Police
– Statements made by the accused to the police under Section 27 of the Indian Evidence Act were presented. However, the court reaffirmed the principle that only information directly leading to the discovery of facts is admissible, and confessions to police are otherwise inadmissible.
4. Circumstantial Evidence
– The court emphasized the stringent standards for convicting based on circumstantial evidence, citing the locus classicus Sharad Birdhichand Sarda v. State of Maharashtra, which outlines that the chain of evidence must be complete and leave no room for alternative hypotheses.
Important Observations by the Supreme Court
– “Human nature is too willing, when faced with brutal crimes, to spin stories out of strong suspicions,” the court remarked, cautioning against convictions based on moral grounds rather than legal evidence.
– “The brutality of the offence does not dispense with the legal requirement of proof beyond a reasonable doubt.”
Decision
The Supreme Court quashed the convictions of the appellants, finding that the prosecution failed to establish their guilt beyond a reasonable doubt. The court criticized the reliance on inadmissible evidence and the withholding of key eyewitness testimony. It emphasized that while the crime was gruesome, the judicial process demands adherence to legal principles.
