In a recent judgment on January 4, 2024, the Supreme Court of India underscored the critical importance of an unbroken chain of circumstances when basing a conviction solely on circumstantial evidence. Justices B R Gavai, P S Narasimha, and Aravind Kumar presided over the case, ultimately leading to the release of Darshan Singh in connection with the 1999 murder of his wife, Amrik Kaur, who allegedly died due to the administration of a poisonous substance, aluminum phosphide. The accused claimed innocence, asserting that his wife had committed suicide following the revelation of her alleged extramarital affair with another woman, Rani Kaur.
The Supreme Court allowed Singh’s appeal against the Punjab and Haryana High Court’s decision that upheld his life sentence. Notably, the co-accused, Rani Kaur, had been acquitted by the High Court, and the state government did not contest this decision.
The case hinged on circumstantial evidence, with the bench highlighting discrepancies in the statements of prosecution witnesses, particularly Melo Kaur and her husband Gurmel Singh, the sister and brother-in-law of the deceased. The court emphasized that any failure to convincingly establish a single circumstance could fracture the chain of events, leading to the benefit of doubt for the accused.
The court elaborated on the principles governing convictions based on circumstantial evidence, emphasizing that the proven circumstances must be complete and exclude any alternative hypothesis except the guilt of the accused. In this case, the court found insufficient evidence to conclusively link the appellant and Rani Kaur to the murder.
The appellant contended that Amrik Kaur had taken her own life due to embarrassment over her extramarital affair with Gurmel Singh. The court noted flaws in Melo Kaur’s testimony, citing omissions and improvements during cross-examination. The bench also questioned the reliability of witnesses who spoke about the accused’s involvement only during the trial and not before the police.
Additionally, the court considered expert opinions on the nature of the poisonous substance, aluminum phosphide, suggesting that its distinct odor would likely be detected. The court cast doubt on the theory of deceitful administration, stating that even if the appellant and Rani Kaur were present, it remained uncertain whether it was a case of homicide or suicide.
Concluding its findings, the bench criticized the High Court’s attempt to distinguish the appellant’s case from Rani Kaur’s, deeming it as flawed and unconvincing. The court highlighted the State’s inconsistent stance on the joint presence of the accused, further contributing to the doubt surrounding the case.
