There cannot be a break in the sequence of events in a case where the conviction is based solely on circumstantial evidence, reiterates the Apex Court.

Darshan Singh v State of Punjab is a 2024 Supreme Court case about a murder conviction based on circumstantial evidence. The defendant was accused of throwing his wife into a canal, where she drowned. It was alleged by the accused that his wife committed suicide. The Supreme Court declared that if the chain of circumstances is broken, the accused is entitled to the benefit of the doubt. The court also found that the prosecution cannot attempt to prove that the witness did not inform the police during the investigation.

LOOKING AT THE FACTS OF THE CASE:

The deceased, Amrik Kaur, married the appellant, Darshan Singh, sometime in 1988. The marriage was planned through the deceased’s cousin sister, Melo Kaur (Prosecution Witness). The prosecution claims that their marriage connection was disrupted primarily because Darshan Singh formed an unlawful partnership with Rani Kaur (Appellant 2). Several family had urged the appellant to discontinue his relationship with Rani Kaur, but to no avail. Darshan Singh and Rani Kaur allegedly had an unlawful connection for at least three years prior to the tragic day. The prosecution claims that on the intervening night of May 18^th 1999, and May 19^th 1999, Darshan Singh and Rani Kaur administered poison and willfully caused Amrik Kaur’s death.

TRIAL COURT and HIGH COURT HELD:

Darshan Singh and Rani Kaur were charged under Section 302 and Section 34 of the Indian Penal Code. The Trial Court convicted both of the defendants for the offense under Section 302 r/w Section 34 and sentenced them to life in prison.

In the appeal, the High Court upheld the Trial Court’s conclusions with regard to the appellant and, by giving Rani Kaur the benefit of the doubt, declared her innocent.

ARGUMENTS OF THE PARTIES:

On the basis of her testimony, it is hoped to show that the appellant, Darshan Singh, was present at the premises on that intervening night. It is not safe to depend on an uncorroborated witness’ testimony, even when she has multiple discrepancies in her testimony. Relying solely on portions of the appellant’s testimony while disregarding the remainder would be unfair to her. There is no other evidence to support the essential circumstance of the appellant’s presence at the scene of the crime if her testimony is disregarded in its entirety.

Because of its strong odor, it is very difficult to inject aluminum phosphide in a dishonest way. The fact that the dead had no visible wounds further proves that the poison could not have been administered violently. As a result, it is argued that this is just a case of suicide.

On the other side, the prosecution stated that since Melo Kaur was illiterate and could not be expected to understand the nuances of cross-examination or the law, it was only natural for a few little anomalies to appear in her testimony. By separating her uncorroborated testimony from her confirmed testimony, the Trial Court has appropriately valued her testimony. To put it another way, the Trial Court has sorted  while evaluating the testimony of a witness who is both trustworthy and partially untrustworthy. Furthermore, the accused has never refuted his attendance at the crime site. He has acknowledged his attendance in his statement recorded under Section 313 of the Cr.P.C. The prosecution has convincingly demonstrated the circumstances that lead to an inference of guilt. The circumstances relied on include the appellant’s motive, presence at the crime scene, cause of death (poisoning), opportunity to administer poison, conduct, and false explanation in the 313 statement.

SUPREME COURT STATED THAT:

The prosecution’s case is based on circumstantial evidence. In a case based on circumstantial evidence, the circumstances leading to an inference of guilt should be clearly proved. To be convicted based on circumstantial evidence, the circumstances must be complete, incapable of explaining any other hypothesis than the accused’s guilt, and inconsistent with their innocence. Given this context, we do not need to assess the evidence relating to other circumstances sought to be proved by the prosecution, because failure to prove a single circumstance convincingly can produce a break in the chain of circumstances. When a conviction is based purely on circumstantial evidence, there should be no break in the chain of events. If some of the events in the chain may be explained by another credible hypothesis, then the accused is also entitled to the benefit of the doubt.

CASE NAME: DARSHAN SINGH VERSUS STATE OF PUNJAB

NAME: Riya Shukla; COURSE: LL.M.(ONE YEAR); COLLEGE: MUIT, Noida; INTERN UNDER LEGAL VIDHIYA.

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