Case Summary: Rajendra Singh & Ors. v. State of Uttaranchal (2025) | Suspicion Cannot Replace Proof Beyond a Reasonable Doubt

This case concerns the appeal of three accused—Rajendra Singh (father), Bhupender Singh (son), and Ranjeet Singh (son-in-law)—against their conviction under Section 302 of the Indian Penal Code (now Section 103(1) of the Bharatiya Nyaya Sanhita) for the murder of Pushpendra Singh, son of the complainant Diler Singh.

The Supreme Court’s judgment, delivered on 7 October 2025, acquitted the appellants and reaffirmed fundamental principles governing appellate interference with acquittal, evidentiary identification, and the admissibility of discovery statements under Sections 25–27 of the Evidence Act.

Background and Procedural History

The incident took place on 3 June 2000 in District Udham Singh Nagar (then part of Uttaranchal). The prosecution alleged that on the morning of the incident, Rajendra Singh and Bhupender Singh were digging the field of Diler Singh to lay a plinth. This sparked an altercation between the two families.

Later that afternoon, around 1:30 p.m., Pushpendra Singh (deceased) was sitting at a place known as Jogither diversion (Tiraha) when the three accused—Rajendra, Bhupender, and Ranjeet Singh—arrived on a motorcycle armed with swords and a kanta (a sharp-edged weapon). Seeing them, Pushpendra ran toward the nearby fields, allegedly chased by the accused. To save himself, he entered the house of one Mukhtyar Singh, where the accused followed and attacked him with the weapons, causing his death on the spot.

The deceased’s father, Diler Singh (PW-1), lodged an FIR the same day at 2:50 p.m. at Police Station Nanak Matta. After the investigation, all three accused were charged under Section 302 read with Section 34 IPC. The Trial Court (Sessions Trial No. 215/2000) acquitted them, holding that the prosecution failed to prove their identity as the assailants beyond a reasonable doubt. The High Court of Uttarakhand, however, reversed the acquittal in Government Appeal No. 347/2007, convicting all three and sentencing them to life imprisonment and a fine of ₹10,000 each on 2 January 2013.

The present criminal appeals (Nos. 476–477 of 2013) were filed before the Supreme Court of India, challenging the High Court’s decision.

Issues Before the Supreme Court

• Whether the identity of the accused as the perpetrators of the murder was established beyond reasonable doubt through credible evidence.
• Whether the High Court was justified in reversing the acquittal by the Trial Court without finding its findings to be perverse.
• Whether the recovery of weapons under Section 27 of the Evidence Act could be relied upon to connect the appellants with the offence.

Arguments Advanced

A. On Behalf of the Appellants

Senior Advocates Rajul Bhargava and Siddharth Agarwal, appearing for the appellants, contended:

• The appellants were falsely implicated due to enmity arising from the morning’s altercation.
• There was no reliable eyewitness to the assault; Amarjeet Kaur (PW-7), the only witness inside the house, did not identify the accused.
• The prosecution’s witnesses, especially PW-1 (Diler Singh) and PW-2 (Jwala Singh), were chance witnesses whose presence was doubtful.
• The recovery of weapons was fabricated and not corroborated by forensic evidence linking blood stains to the deceased.
• The High Court erred in overturning an acquittal without proving perversity in the Trial Court’s findings.

B. On Behalf of the State

The State’s counsel Kuldeep Parihar, D.A.G., and Anubha Dhulia argued:

• Multiple witnesses had seen the accused chasing the deceased, confirming their identity.
• PW-7 Amarjeet Kaur clearly described the three assailants entering her house and killing the deceased.
• Her blood-stained clothes and seized bedsheet, confirmed by FSL report, established her presence and the authenticity of the crime.
• The recovered weapons were found based on the disclosure statements of the accused, which further corroborated their involvement.

Court’s Analysis and Findings

1. Ocular Testimony and Identification of the Accused

The Supreme Court meticulously examined the eyewitness testimonies, particularly those of PW-7 Amarjeet Kaur, PW-1 Diler Singh, and PW-2 Jwala Singh.

(a) Testimony of PW-7 Amarjeet Kaur

Amarjeet Kaur, wife of Mukhtyar Singh, in whose house the crime occurred, testified that three unknown men entered her house carrying swords and other sharp weapons and attacked a young man who ran inside seeking refuge.

• She tried to restrain them and, in that process, her clothes were stained with blood.
• After the assault, the men left; soon after, the deceased’s father and others arrived.
• She clearly stated that she did not know the names of the assailants and was never asked to identify them later.

The Court held that while PW-7’s testimony confirmed the occurrence of the murder, it did not establish the identity of the accused as the perpetrators. Moreover, no test identification parade (TIP) was conducted to link the accused to the crime.

(b) Testimony of PW-1 Diler Singh

PW-1 claimed that he saw the appellants chasing his son with swords and kanta, followed them for 10–15 minutes, and saw them enter Mukhtyar Singh’s house and kill his son.

However, his account raised multiple inconsistencies:

• He admitted that the site of the attack (Jogither diversion) was 1.5 km away from his house and not on his route from the flour mill, suggesting he was a chance witness.
• He claimed to have reached the scene immediately, but PW-7 said the father arrived half an hour later.
• He stated that his clothes were stained with blood after hugging his son, yet police never seized or recorded this evidence.

The Court found these contradictions material, holding that PW-1’s presence at the scene during the assault was highly doubtful and his testimony unreliable.

(c) Testimony of PW-2 Jwala Singh

Jwala Singh, allegedly following PW-1 by 60–70 steps, also claimed to have seen the chase. However, since PW-1’s presence itself was doubtful, PW-2’s testimony too lost credibility.

He was another chance witness who failed to satisfactorily explain his presence near the scene.

(d) Corroborative Witnesses Absent

Despite several shopkeepers and field labourers allegedly witnessing the chase, none were examined. Even PW-4 Kakka Singh, the flour mill owner, did not confirm PW-1’s presence at his mill, further undermining the prosecution’s story.

The Supreme Court concluded that no reliable ocular evidence established the identity of the accused as the killers.

2. Evidentiary Value of Recovery under Section 27 of the Evidence Act

The prosecution heavily relied on the recovery of swords and a kanta based on the accused’s disclosures. The Court, however, observed:

• One sword was recovered from a garage, and the others from an open sugarcane field, accessible to many.
• No forensic link between the weapons and the deceased’s blood was established.
• The FSL report was never produced to show blood traces matching the victim.

The Court clarified the scope of Sections 25, 26, and 27 of the Evidence Act, 1872, emphasising that:

• Sections 25 & 26 prohibit confessions made to police or in police custody from being proved against an accused.
• Section 27 is a limited exception, allowing proof only of the information that distinctly leads to the discovery of a fact, not of any confession of guilt.

Relying on Pulukuri Kottaya v. King Emperor (1947 MWN Cr 45) and reaffirming Manjunath v. State of Karnataka (2023 SCC OnLine SC 1421), the Court reiterated that:

“Only that portion of the accused’s statement which distinctly relates to the discovery of a fact is admissible; the rest, including any confession of guilt, must be excluded.”

Therefore, the alleged disclosure—“we hid the weapons used in the offence”—could not be used to prove guilt. Without scientific corroboration, the recoveries had no evidentiary value.

3. Appellate Interference with Acquittal

The Supreme Court strongly reiterated the settled law that an order of acquittal can be interfered with by an appellate court only when the findings of the trial court are perverse or wholly unreasonable. The Trial Court, having observed the witness's demeanour firsthand, had rightly acquitted the accused for want of identification and credibility of evidence.

The High Court, however, failed to record any finding of perversity or error in the Trial Court’s judgment before reversing it. The Supreme Court held that:

“It is safer and more appropriate to rely upon the findings of the Trial Court which has seen the demeanour of the witnesses rather than on those of the First Appellate Court.”

Since the High Court’s reversal lacked this foundational reasoning, the Supreme Court found its decision legally unsustainable.

Decision

The Supreme Court held that:

• The prosecution failed to establish the identity of the accused beyond a reasonable doubt.
• The recovery of weapons did not connect the appellants to the crime.
• The High Court erred in reversing the trial court’s well-reasoned acquittal without demonstrating perversity.

Consequently, the Court set aside the conviction and sentence imposed by the High Court, allowed the appeals, and acquitted all appellants, granting them the benefit of doubt.

Their bail bonds were discharged accordingly.

Click Here to Read the Official Judgment

Conclusion

The Supreme Court’s judgment in Rajendra Singh & Ors. v. State of Uttaranchal is a vital reaffirmation of criminal procedural safeguards and evidentiary standards. It reminds the prosecution of the necessity to ensure robust identification, scientific corroboration, and procedural fairness.

By acquitting the appellants, the Court not only corrected an evidentiary error but also reinforced the balance between crime control and due process—a cornerstone of Indian criminal jurisprudence.

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