Supreme Court Acquits Death Row Convicts Citing 'Riddled' Investigation

The Supreme Court in Mehtab v. State of Uttarakhand set aside the death sentences of two men, observing that the prosecution had failed to establish a complete and unbroken chain of circumstances pointing unerringly to their guilt.

A three-judge bench comprising Justice Vikram Nath, Justice Sandeep Mehta, and Justice Vijay Bishnoi delivered the judgment, setting aside the convictions recorded under the Indian Penal Code, 1860 and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Court emphasized that in cases resting solely on circumstantial evidence, suspicion however grave cannot take the place of legal proof.

Court Challenges Reliability of 'Last Seen' Theory

The prosecution had primarily relied on the 'last seen together' circumstance, supported by the testimonies of two witnesses who allegedly saw the appellants enquiring about the deceased-victim before her body was found. However, the Bench found glaring inconsistencies in the preparation of sketches and the subsequent identification of the accused. The Court noted with concern that the sketch artist remained anonymous and the original sketches were never produced.

Failure to Conduct Test Identification Parade

The Bench highlighted a critical lapse in the investigative process regarding the identification of the accused. Since the appellants were previously unknown to the material witnesses, the failure to conduct a Test Identification Parade (TIP) was deemed fatal to the prosecution's case. The Court observed that identifying the accused for the first time in the dock, after a considerable lapse of time, lost all evidentiary significance.

Integrity of Forensic Evidence and Recoveries Questioned

One of the most incriminating pieces of evidence a torn shirt pocket allegedly found at the crime scene was dismissed by the Court as a 'created circumstance'. The Bench noted that the pocket appeared to have been carefully unpicked rather than violently torn during a scuffle. Furthermore, the Court found the recovery of the victim's clothes and ornaments pursuant to disclosure statements to be highly suspicious and likely 'planted'.

Broken Chain of Custody for Forensic Samples

The Court scrutinized the handling of forensic samples, finding no reliable evidence to establish their safe custody from the time of seizure until they reached the Forensic Science Laboratory (FSL). The Bench remarked: "In the absence of a duly proved chain of custody, the sanctity and integrity of the forensic samples become doubtful and, consequently, the scientific reports based thereon lose their evidentiary value."

The Court, in its reasoning, observed: "Each circumstance forming part of the chain must stand independently established and the cumulative effect thereof must be such as to lead only to the irresistible conclusion that the accused alone is the perpetrator of the crime. Mere suspicion, however grave, cannot take the place of legal proof, and the circumstances proved must be incompatible with the innocence of the accused."

Court Directions

The Court has the following directions:

"The appeals are allowed. The impugned judgment of conviction dated 23rd January, 2014 and order of sentence dated 27th January, 2014 passed by the trial Court and the common judgment dated 27th April, 2018 passed by the High Court are hereby set aside. The conviction of the appellants and the sentences awarded to them, by the trial Court and affirmed by the High Court are also set aside. The appellants are acquitted of all the charges levelled against them. They are in jail and shall be released from custody forthwith, if not wanted in any other case."

Background:

The case involved the brutal rape and murder of a 55-year-old woman who had gone to the forest for grazing goats in December 2012. The Trial Court had awarded the death sentence to the appellants for offences under Section 302 read with Section 34 of the Indian Penal Code, 1860, along with life imprisonment for rape and atrocities. The High Court of Uttarakhand maintained the conviction and confirmed the death reference in 2018. The appellants challenged these findings before the Supreme Court, arguing that the case was fabricated and built on investigative lapses. The Supreme Court eventually concluded that the prosecution failed to prove the charges beyond reasonable doubt and granted the benefit of doubt to the appellants, leading to their acquittal.

Case Details:
Case No.: CRIMINAL APPEAL NO(S). 1342-1343 OF 2018
NeutralCitation: 2026 INSC 578
Case Title: MEHTAB v. STATE OF UTTARAKHAND
Appearances:
For the Petitioner(s): Mr. A. Sirajudeen, Senior Counsel

Source: 2026 CaseBase(SC) 500