SUPREME COURT REITERATES REQUIREMENT FOR PROOF BEYOND REASONABLE DOUBT IN CIRCUMSTANTIAL EVIDENCE CASE

SUPREME COURT REITERATES REQUIREMENT FOR PROOF BEYOND REASONABLE DOUBT IN CIRCUMSTANTIAL EVIDENCE CASE

The Supreme Court, in a powerful judgment in the case of Putai v. State of Uttar Pradesh [Criminal Appeal Nos. 36-37 of 2019 with 154 of 2025], rigorously examined the evidentiary standards required in criminal trials, particularly those relying exclusively on circumstantial evidence.

Delivered by Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta, this decision carries significant consequences for the administration of criminal justice, reinforcing core principles that safeguard the rights of the accused.

This decision by a Three-Judges Bench stresses the necessity for a clear and unbroken chain of evidence before holding any individual guilty, especially in cases carrying the gravest penalties, and sets a crucial precedent for fair trials and the protection of due process.

BACKGROUND OF THE CASE

The tragic incident at the center of this case involved the brutal rape and murder of a minor girl in Lucknow, Uttar Pradesh, in September 2012. The disappearance of the 12-year-old was reported by her parents after she failed to return home one evening. Her body was subsequently found in a nearby field, with several personal items, including chappals and a water canister, discovered in an adjacent field cultivated by one of the accused.

The investigation led police to arrest two neighbors, Putai and Dileep, largely on the basis of circumstantial evidence, such as the location of the child’s belongings and the use of a sniffer dog that allegedly traced a comb back to one of the accused. Despite initial inconclusive DNA results, a supplementary DNA report, introduced only at the appellate stage, claimed a match with the Accused.

COURT’S ANALYSIS AND FINDING

1. Chain of Circumstantial Evidence not complete: The Supreme Court found several inconsistencies and gaps in the prosecution’s case. The original FIR did not implicate the accused, and the testimonies of key witnesses (including the victim’s parents) failed to establish any direct connection. The physical evidence placed in the fields was deemed accessible to the public, and thus insufficient to single out the Accused.
2. Serious doubts in forensic evidence: The Bench noted major procedural lapses concerning the collection, custody, and documentation of forensic samples. Not only were there discrepancies in the numbers and handling of forensic slides, but the key supplementary DNA report was presented without proper expert testimony or opportunity for the Accused to respond, rendering it inadmissible.
3. Deficiencies in Investigation: The Judgment sharply criticized the investigation, highlighting failures such as the non-examination of relevant witnesses, absence of a credible chain of custody for evidence, no proper identification of recovered articles, and the lack of documents confirming the process of collecting blood samples from the Accused.
4. Presumption and suspicion are not proof: The Court reiterated that, under criminal law, the Prosecution must prove its case beyond a reasonable doubt. Circumstantial evidence must form a complete chain that points solely to the guilt of the Accused. Any significant break or alternative possibility entitles the accused to acquittal.
5. Planted recoveries and exaggerated testimony: The Court considered the possibility that certain pieces of evidence, such as the underwear allegedly recovered from a field, may have been planted to bolster the prosecution case. Additionally, it noted that conduct described by witnesses (such as an accused washing his face after a day’s work) was entirely innocuous and could not be considered incriminating.

DIRECTIONS OF THE COURT

• The Supreme Court set aside both the Trial Court and High Court Judgments, holding that the necessary threshold of proof had not been met for a conviction. Both Appellants were acquitted and ordered to be released from custody unless wanted in another case.
• The Court lamented the investigation’s shortcomings, denouncing the lack of diligence in gathering and presenting reliable evidence, especially in a case involving such a grave crime.

KEY TAKEAWAYS FROM THE JUDGEMENT

1. The Prosecution must prove guilt beyond reasonable doubt, especially in cases based solely on circumstantial evidence.
2. Forensic evidence without a proven chain of custody or proper expert examination cannot be relied upon for conviction.
3. Abnormal conduct or mere suspicion cannot substitute for legal proof.
4. Lapses or exaggerations in testimony, and planted or improperly documented evidence, undermine the entire case.
5. The criminal justice system must guard against miscarriages of justice, even in the face of terrible crimes.

CONCLUSION

This ruling is a compelling reaffirmation of the core principles of criminal law: the presumption of innocence and the demanding standard of proof required to convict. The Supreme Court’s detailed analysis serves as a powerful reminder to investigative agencies and courts to maintain the highest procedural standards, ensuring not just punishment for the guilty, but protection for the innocent as well.

Soumen Dash
(Legal Associate)

The Indian Lawyer & Allied Services

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