IN THE SUPREME COURT OF INDIA
CRIMINAL APPELLATE JURISDICTION
RANDEEP SINGH @ RANA & ANR. … APPELLANTS
versus
STATE OF HARYANA & ORS. … RESPONDENTS
Citation: 2024 INSC 887
Bench in the case:
- Justice Abhay S. Oka
- Justice Ahsanuddin Amanullah
- Justice Augustine George Masih
Abstract
The Supreme Court’s decision in Randeep Singh @ Rana & Anr. vs. State of Haryana & Ors. provides a critical interpretation of evidentiary standards and safeguards enshrined in the Indian legal system. It reinforces the principle that only legally admissible evidence can form the basis of conviction, especially in cases hinging on circumstantial evidence. The judgment underscores the inadmissibility of police confessions under Sections 25 and 26 of the Indian Evidence Act, 1872, and clarifies the narrow scope of admissibility under Section 27.
This analysis explores the judicial reasoning, procedural lapses, and legal implications of the case, emphasizing its impact on criminal jurisprudence.
Introduction
Criminal trials demand the highest standards of evidence to ensure fairness and justice. In Randeep Singh, the Supreme Court acquitted the accused due to lapses in procedural compliance and reliance on inadmissible evidence. This judgment provides a comprehensive framework for applying Sections 25-27 of the Indian Evidence Act, 1872 (hereinafter, the Evidence Act). The case involved circumstantial evidence, eyewitness testimony, and electronic evidence, all of which were scrutinized under rigorous legal principles.
Case Background
Facts of the Case
On July 8, 2013, Gurpal Singh was abducted and later brutally murdered. His dismembered body was recovered the following day. Eight individuals, including the appellants, were charged with the offences of murder (Section 302), abduction (Section 364), criminal conspiracy (Section 120B), and other related charges under the Indian Penal Code, 1860 (IPC).
The Sessions Court convicted all eight accused, sentencing them to life imprisonment. The High Court partially overturned the judgment, acquitting some while upholding the convictions of the appellants. The appellants appealed to the Supreme Court, challenging the admissibility of evidence and procedural irregularities.
Legal Issues
1. Scope of Section 27 of the Evidence Act
Section 27 permits the admissibility of statements made by an accused in custody only to the extent that such statements distinctly relate to facts discovered as a result of the information provided.
Supreme Court’s Clarification
The Court clarified that:
- Only specific portions of a statement directly linked to discovery are admissible. Confessions about involvement in a crime are inadmissible under Sections 25 and 26.
- Statements must be limited to discovered facts. Broader confessions should not be incorporated in deposition or relied upon by the prosecution.
Judicial Critique of the Trial Court
Justice Abhay S. Oka criticized the trial court for allowing the investigating officer (PW-27) to include inadmissible portions of the accused’s statements in his examination-in-chief. The Court observed:
“There is a complete prohibition on even proving such confessions. The learned Trial Judge has completely lost sight of Sections 25 and 26 of the Evidence Act and has allowed PW-27 to prove the confessions allegedly made by the accused while they were in police custody.”
Key Observations from the Judgment
- Statements in Exhibits P55 and P56 allegedly included the accused confessing to:
- Their involvement in the murder.
- The disposal of the deceased’s body.
- Other details beyond the scope of discovery.
- These portions, being inadmissible, should have been excluded from the deposition.
The Court reiterated:
“What is admissible is only such information furnished by the accused as relates distinctly to the facts thereby discovered. No other part is admissible.”
This misapplication of Section 27 led the Supreme Court to express concern over trial courts being unduly influenced by inadmissible confessions.
2. Admissibility of Eyewitness Testimony
Eyewitness testimony (PW-26) was critical to the prosecution’s case but was found unreliable due to material omissions.
Legal Inconsistencies
- PW-26’s initial statement under Section 161 of the CrPC omitted crucial details, such as the identification of the accused or the vehicle involved.
- The co-witness, her husband, was neither examined nor his statement recorded, violating Section 162 of the CrPC.
Judicial Reasoning
The Court ruled that PW-26’s testimony lacked credibility due to contradictions and her failure to identify the accused in a test identification parade.
3. Admissibility of Electronic Evidence
CCTV footage allegedly capturing the abduction was deemed inadmissible due to procedural lapses under Section 65B of the Evidence Act.
Requirements under Section 65B
- A certificate authenticating the electronic record.
- Identification of the device used to produce the footage.
- Certification of the data’s integrity.
Prosecution’s Failures
- No Section 65B certificate was produced.
- Witnesses PW-1 and PW-24 admitted they neither verified the footage nor sealed the evidence.
- Tampering concerns were raised as the footage lacked markings.
The Supreme Court, relying on Anvar P.V. v. P.K. Basheer, excluded the footage, stating that procedural compliance was mandatory for admissibility.
4. Circumstantial Evidence and Legal Standards
The prosecution’s case was primarily based on circumstantial evidence, which must satisfy the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra:
- Circumstances must be fully established.
- They should point exclusively to the guilt of the accused.
- They must exclude all other hypotheses.
Evaluation of Evidence
- Recovery of Items: The prosecution relied on the recovery of a vehicle and weapon allegedly linked to the crime. However, these recoveries were not conclusively tied to the appellants.
- Chain of Events: The Court held that the evidence failed to establish a complete and unbroken chain pointing to the appellants’ guilt.
Judgment
Supreme Court’s Findings
- The entire prosecution case relied on circumstantial evidence, which failed to meet the standards of proof beyond a reasonable doubt.
- Procedural violations, including the improper inclusion of inadmissible confessions, undermined the fairness of the trial.
The Court acquitted the appellants, emphasizing:
“The brutality of the offence does not dispense with the legal requirement of proof beyond a reasonable doubt. The Courts can convict an accused only if his guilt is proved beyond a reasonable doubt on the basis of legally admissible evidence.”
Implications for Criminal Jurisprudence
1. Strict Standards for Admissibility
The judgment reinforces procedural safeguards for electronic and confessional evidence, ensuring adherence to Sections 25-27 and 65B of the Evidence Act.
2. Protecting Fair Trial Principles
The exclusion of inadmissible evidence safeguards the accused’s rights under Article 21 of the Constitution, promoting judicial impartiality.
3. Circumstantial Evidence Scrutiny
The case underscores the need for robust evidence chains, ruling out alternative hypotheses to secure convictions.
Conclusion
The Randeep Singh judgment is a cornerstone in Indian criminal jurisprudence, reinforcing evidentiary and procedural safeguards. It serves as a reminder that convictions must rest on unassailable legal foundations, preserving the balance between justice and individual rights. The Supreme Court’s meticulous analysis of Sections 25-27 and its emphasis on procedural compliance make this case a guiding precedent for future trials.
Reference
- Indian Penal Code, 1860, §§ 302, 364, 120B.
- Indian Evidence Act, 1872, §§ 25-27, 65B.
- Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116.
- Anvar P.V. v. P.K. Basheer, (2014) 10 SCC 473.
- Pulukuri Kotayya v. King-Emperor, AIR 1947 PC 67.
- Subhash Chand v. State of Rajasthan, (2002) 1 SCC 702.
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