Convictions Quashed After Court Finds Circumstantial Case Collapses; Accused Acquitted and Ordered Released

A bench of Justices Manoj Misra and Sandeep Mehta heard the appeal arising from convictions in a 1997 murder case and considered whether circumstantial and extra‑judicial confession evidence sufficed to sustain convictions under Sections 302 and 201 IPC. The appeal challenged the High Court’s affirmance of life sentences imposed by the trial court.

The Court allowed the appeal, quashed the judgments of the trial court and the High Court, and acquitted the appellant Shanti Devi and her son Rajbir of all charges, directing their release if not wanted in any other case. The Court emphasised that the prosecution’s case rested entirely on circumstantial evidence and must satisfy the well‑known tests laid down in Sharad Birdhichand Sarda v. State of Maharashtra. The Court, in its reasoning, observed: “A close analysis of this decision would show that the following conditions must be fulfilled before a case against an accused can be said to be fully established: (1) the circumstances from which the conclusion of guilt is to be drawn should be fully established... (2) the facts so established should be consistent only with the hypothesis of the guilt of the accused... (3) the circumstances should be of a conclusive nature and tendency, (4) they should exclude every possible hypothesis except the one to be proved, and (5) there must be a chain of evidence so complete as not to leave any reasonable ground for the conclusion consistent with the innocence of the accused...” The Court found that the prosecution “failed to prove” a complete chain of incriminating circumstances and that the “theory of extra‑judicial confessions is palpably false.” It also held that the recoveries were under “a grave cloud of doubt” and that the negative FSL report rendered the alleged recoveries inconsequential.

Background: The prosecution alleged that Balwant was murdered in December 1997 and his body was concealed in a gunny bag and dumped in a waterworks tank. The trial court convicted Shanti Devi, her son Rajbir and another accused, Veena, for murder and related offences; Veena’s appeal abated on her death. The High Court dismissed appeals by Shanti Devi and Rajbir, prompting this special leave petition by Shanti Devi.

Prosecution relied on motive (possession dispute and alleged illicit relations), a last‑seen testimony, extra‑judicial confessions attributed to the accused given to unrelated persons, and recoveries (weapons, chaddar) said to have been effected at the accuseds’ instance. Post‑mortem showed multiple ante‑mortem injuries and cause of death as fracture of the frontal bone with intracerebral hemorrhage.

On review, the Supreme Court found critical defects: the informant’s testimony on motive was internally inconsistent (forcible occupation vs. tenancy) and his knowledge of the deceased’s affairs was limited; the Court treated the extra‑judicial confessions as weak and observed that confessions made in the presence of police were inadmissible except under narrowly defined circumstances. The Court noted that recovery witnesses and confession witnesses were unconnected to the accused and appeared to be “got up” witnesses. The FSL report did not detect human blood on the weapons and offered no conclusive serological linkage; weapons were not even sent for serology. Finding the chain of circumstances incomplete and unreliable, the Court held that both lower courts erred in affirming conviction. The Court acquitted Shanti Devi and, suo motu, extended the benefit to Rajbir though he had not appealed, and ordered their release if not wanted in other cases. The appeal was allowed and pending applications were disposed.

Case Details: Case No.: CRL. APPEAL NO(S). 2861 OF 2025 Case Title: Shanti Devi v. State of Haryana Appearances: For the Petitioner(s): [Not indicated in the judgment] For the Respondent(s): [Not indicated in the judgment]