A) ABSTRACT / HEADNOTE

The Supreme Court adjudicated on whether Darshan Singh could be convicted solely on circumstantial evidence for the alleged murder of his wife, Amrik Kaur, with assistance from Rani Kaur. The prosecution argued that Darshan Singh and Rani Kaur, who had an illicit relationship, poisoned Amrik Kaur to eliminate her. Despite the Trial Court’s conviction of both Darshan Singh and Rani Kaur, the High Court acquitted Rani Kaur. Darshan Singh‘s appeal raised significant doubts regarding the prosecution’s reliance on circumstantial evidence. Key issues included the credibility of witness testimonies, the possibility of suicide, and the sufficiency of evidence to firmly establish the chain of circumstances leading to Darshan Singh’s conviction. Ultimately, the Supreme Court found the prosecution’s evidence insufficient to exclude the hypothesis of suicide, granting Darshan Singh the benefit of the doubt.

Keywords: Circumstantial Evidence, Suicide, Benefit of Doubt, Illicit Relationship, Prosecution Witness Credibility

B) CASE DETAILS

• i) Judgement Cause Title: Darshan Singh v. State of Punjab
• ii) Case Number: Criminal Appeal No. 163 of 2010
• iii) Judgement Date: 04 January 2024
• iv) Court: Supreme Court of India
• v) Quorum: Justice B. R. Gavai, Justice Pamidighantam Sri Narasimha, and Justice Aravind Kumar
• vi) Author: Justice Aravind Kumar
• vii) Citation: [2024] 1 S.C.R. 248 : 2024 INSC 19
• viii) Legal Provisions Involved: Indian Penal Code, 1860 – Sections 302 and 34; Code of Criminal Procedure, 1973 – Sections 161 and 313
• ix) Judgments Overruled by the Case: None specified
• x) Related Law Subjects: Criminal Law, Evidence Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appellant, Darshan Singh, faced conviction based on allegations that he, with Rani Kaur, his alleged partner, poisoned Amrik Kaur, his wife. The prosecution’s case relied solely on circumstantial evidence, claiming Darshan Singh and Rani Kaur’s presence at the scene and Darshan Singh‘s motive, linked to his relationship with Rani Kaur. The Supreme Court’s examination centered on the reliability of witness testimonies and the strength of circumstantial evidence. The judgment scrutinized whether Darshan Singh’s conviction could stand given the lack of direct evidence and plausible alternative explanations.

D) FACTS OF THE CASE

Amrik Kaur married Darshan Singh in 1988, and their marriage became strained due to Darshan Singh’s alleged affair with Rani Kaur. The prosecution alleged that on the night of 18-19 May 1999, Darshan Singh and Rani Kaur poisoned Amrik Kaur to remove her from their lives. Darshan Singh and Rani Kaur were initially convicted by the Trial Court, but on appeal, the High Court acquitted Rani Kaur due to lack of direct evidence of her presence on that night. The case hinged on circumstantial evidence and witness testimonies, particularly from PW3 (Melo Kaur) and PW4 (Gurmel Singh).

E) LEGAL ISSUES RAISED

1. Whether the prosecution established an unbroken chain of circumstances leading to Darshan Singh’s guilt.
2. Whether circumstantial evidence and the testimonies of PW3 and PW4 were sufficient to prove Darshan Singh’s presence at the scene.
3. Whether the appellant could be convicted based solely on circumstantial evidence in the absence of direct eyewitnesses.
4. Whether the inconsistencies and omissions in witness testimonies created reasonable doubt.

F) PETITIONER/APPELLANT’S ARGUMENTS

The counsel for Darshan Singh argued:

1. Unreliable Testimonies: PW3 (Melo Kaur) and PW4 (Gurmel Singh) presented inconsistencies and omitted key details in their statements under Section 161 of CrPC, undermining their reliability. Such omissions could not substantiate Darshan Singh‘s presence at the crime scene.

2. Natural Possibility of Suicide: The pungent odor and toxic nature of aluminium phosphide made deceitful administration highly unlikely. No injury marks were found on Amrik Kaur, making forced administration implausible, supporting the hypothesis of suicide.

3. Precedent Supporting Inconsistencies: Rulings in Rohtash v. State of Haryana [(2012) 6 SCC 589] and Sunil Kumar Shambhu Dayal Gupta v. State of Maharashtra [(2011) 72 ACC 699] established that improvements and omissions in witness testimonies diminish their evidentiary value.

4. Prejudiced Burden of Proof: The High Court extended the benefit of doubt to Rani Kaur but maintained Darshan Singh’s conviction without consistent reasoning, indicating biased reliance on circumstantial evidence.

G) RESPONDENT’S ARGUMENTS

The State of Punjab, represented by counsel, contended:

1. Credibility of an Illiterate Witness: The State argued that PW3’s minor inconsistencies should not discount her testimony, as she was an illiterate witness and unable to recount precise legal details. Her testimony, coupled with PW4 and PW5‘s depositions, established Darshan Singh’s presence.

2. Circumstantial Evidence as Sufficient Proof: As per Trimukh Maroti Kirkan v. State of Maharashtra [(2006) 10 SCC 681], circumstantial evidence can form a basis for conviction if the defendant fails to offer credible explanations under Section 106 of the Evidence Act.

3. Evidence Chain Supporting Guilt: The State cited motive, presence, and the doctor’s opinion on death by poisoning as forming a comprehensive chain of evidence implicating Darshan Singh.

H) JUDGEMENT

a. Ratio Decidendi

The Court concluded that Darshan Singh‘s conviction could not stand solely on circumstantial evidence due to unreliable testimonies and failure to exclude the hypothesis of suicide. It held that witness inconsistencies and omissions disrupted the chain of evidence, entitling Darshan Singh to the benefit of the doubt.

b. Obiter Dicta

The Court noted that in cases relying on circumstantial evidence, each link must be unbroken to eliminate alternative hypotheses, emphasizing strict scrutiny of witness credibility.

c. Guidelines

1. Evaluation of Evidence: Courts should meticulously evaluate inconsistencies in witness statements under Section 161 of CrPC.
2. Circumstantial Evidence Standards: Convictions based on circumstantial evidence must establish a chain without gaps.
3. Benefit of Doubt Principle: Courts should extend the benefit of doubt when multiple interpretations are plausible.

I) CONCLUSION & COMMENTS

The judgment underscores the judiciary’s rigorous approach in cases reliant on circumstantial evidence, stressing the need for coherence and reliability in witness testimonies. The Court highlighted the importance of an unbroken chain of circumstances to convict solely on circumstantial evidence. The case also illustrates the protective application of the benefit of doubt principle, especially in the face of inconsistent witness testimonies and plausible alternative scenarios, such as suicide. The verdict reinforces defendants’ right to challenge evidence gaps and seeks to balance judicial scrutiny in circumstantial cases with evidentiary safeguards.

J) REFERENCES

a. Important Cases Referred

1. Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116
2. Trimukh Maroti Kirkan v. State of Maharashtra (2006) 10 SCC 681
3. Rohtash v. State of Haryana (2012) 6 SCC 589
4. Sunil Kumar Shambhu Dayal Gupta v. State of Maharashtra (2011) 72 ACC 699
5. Jaipal v. State of Haryana (2003) 1 SCC 169

b. Important Statutes Referred

1. Indian Penal Code, 1860 – Section 302, Section 34
2. Code of Criminal Procedure, 1973 – Section 161, Section 313
3. Evidence Act – Section 106