SC sets aside convictions of Rajendra Singh & ors., holding High Court erred in reversing Trial Court acquittal in murder case.

Headnote:

The Supreme Court of India, Criminal Appellate Jurisdiction, allowed Criminal Appeals Nos. 476-477 of 2013 filed by Rajendra Singh and others, challenging the High Court of Uttarakhand’s judgment convicting them under Section 302 IPC. The appellants, father, son, and son-in-law, were accused of murdering Pushpendra Singh. The Trial Court had acquitted them, but the High Court reversed the acquittal and sentenced them to life imprisonment with a fine of Rs.10,000 each. The apex court held that the identity of the appellants was not established by reliable ocular evidence or recovery of weapons. Testimonies of key witnesses were found inconsistent, and Section 27 of the Evidence Act clarified that only information leading to discovery of weapons is admissible, not statements admitting the crime. The Court emphasized that the High Court erred in interfering with the acquittal without finding the Trial Court’s findings perverse.

Background:

The appellants were accused of murdering Pushpendra Singh on 03.06.2000 after an altercation over digging Diler Singh’s field. The prosecution relied primarily on testimonies of PW-1 (father of deceased), PW-2 (Jwala Singh), and PW-7 (Amarjeet Kaur). PW-7’s testimony indicated that the assailants were unknown to her, undermining identification claims. No identification parade was conducted. Weapons were allegedly recovered based on appellants’ disclosures, but no forensic evidence linked them to the crime. The Trial Court acquitted the appellants, whereas the High Court reversed the acquittal.

Court Opinion/Analysis:

The Supreme Court found that the High Court erred in reversing the Trial Court’s acquittal. Ocular evidence was insufficient to identify the appellants, and the recovery of weapons alone did not establish guilt. The Trial Court’s findings, which observed witness demeanor, were more reliable. The Court allowed the appeals, set aside the convictions, and acquitted the appellants, granting them the benefit of doubt. Bail bonds were discharged.

Legal Provisions Invoked:

Section 302 IPC – Punishment for murder

Sections 25, 26, 27 Indian Evidence Act, 1872 – Admissibility of confessions and discovery of facts from accused in police custody

Key Legal Principles:

1. Acquittal by Trial Court cannot be disturbed absent perversity
2. Ocular evidence and recovery of weapons must establish identity of accused
3. Section 27 allows admissibility only for facts discovered, not confessions of crime
4. Benefit of doubt applies when evidence is insufficient or contradictory

Case Details:

Court: Supreme Court of India

Judges: Hon’ble Mr. Justice Pankaj Mithal & Hon’ble Mr. Justice Prasanna B. Varale

Date of Order: 07.10.2025

Criminal Appeal Nos.: 476-477 of 2013