Darshan Singh v State of Punjab (2024)

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Case Name: Darshan Singh v State of Punjab

Court: Supreme Court of India
Judgement Date: 4th January, 2024
Bench: Justice B.R. Gavai, Justice P.S. Narasimha, Justice Aravind Kumar

Facts of Darshan Singh v State of Punjab

Darshan Singh v State of Punjab case revolves around the strained marital relationship between Darshan Singh (the appellant) and the deceased, Amrik Kaur. Their discord was primarily due to Darshan Singh’s illicit relationship with Rani Kaur, which lasted for over three years. The prosecution alleged that this extramarital affair motivated Darshan Singh and Rani Kaur to eliminate Amrik Kaur.

On the night of May 18-19, 1999, it was alleged that Darshan Singh and Rani Kaur administered poison to Amrik Kaur, resulting in her death. The two accused were charged under Section 302 read with Section 34 of the Indian Penal Code (IPC), denoting murder with common intent.

The Trial Court convicted both Darshan Singh and Rani Kaur, sentencing them to life imprisonment. However, upon appeal, the High Court upheld Darshan Singh’s conviction but acquitted Rani Kaur, granting her the benefit of doubt. Dissatisfied with the judgement, Darshan Singh approached the Supreme Court, challenging his conviction.

Key Issues

The issues raised in Darshan Singh v State of Punjab were:

  1. Whether the statement recorded under Section 313 of the Code of Criminal Procedure, 1973, can form the sole basis for conviction?
  2. Whether the prosecution’s evidence was sufficient to uphold the conviction of Darshan Singh?
  3. How should omissions and contradictions in witness testimonies be treated in criminal cases?

Relevant Provisions

  1. Section 302 IPC: Punishment for murder.
  2. Section 34 IPC: Acts done by several persons in furtherance of common intention.
  3. Section 313 CrPC: Power to examine the accused, enabling the court to question the accused on the evidence presented against them.

Arguments by the Appellant (Darshan Singh)

  1. The appellant contended that the evidence relied upon by the prosecution was inadequate to establish guilt beyond a reasonable doubt.
  2. It was argued that there were significant omissions in the witness testimonies, weakening the prosecution’s case.
  3. The appellant emphasised that his statement recorded under Section 313 CrPC could not serve as the sole basis for his conviction, as it did not qualify as substantive evidence.
  4. He further argued that the High Court erred in distinguishing between him and Rani Kaur, acquitting her while upholding his conviction without sufficient justification.

Arguments by the Respondent (State of Punjab)

  1. The prosecution argued that the marital discord and the motive arising from the extramarital affair provided strong circumstantial evidence against the appellant.
  2. It was asserted that the sequence of events, coupled with the toxicological findings, pointed to Darshan Singh’s involvement in the crime.
  3. The state maintained that the omissions in witness testimonies were not material enough to absolve the appellant of guilt.
  4. The prosecution relied on the appellant’s responses under Section 313 CrPC, arguing that they indicated a consciousness of guilt.

Darshan Singh v State of Punjab Judgement

Evaluation of Witness Testimonies

The Court meticulously analysed the testimonies of the prosecution witnesses (PWs) and identified significant omissions and contradictions. These discrepancies undermined the reliability of the evidence presented during the trial. The Court reaffirmed the principle that evidence introduced for the first time during the trial, if not recorded in statements under Section 161 CrPC during the investigation, cannot be relied upon.

Role of Section 313 CrPC

The Court clarified the limited evidentiary value of an accused’s statement under Section 313 CrPC:

  • Such a statement is not given under oath, and the prosecution does not have the opportunity to cross-examine the accused.
  • Consequently, it cannot be treated as substantive evidence or serve as the sole basis for conviction.
  • The Court cited Sidhartha Vashisht vs. State of NCT of Delhi (2010) and Pramila vs. State of Uttar Pradesh (2021) to emphasise that an omission under Section 313 does not denude an accused of their right to establish a defence by other means.

Circumstantial Evidence

In cases relying on circumstantial evidence, the Court reiterated the standard principles:

  • The chain of circumstances must be complete, leading unequivocally to the conclusion that the accused committed the crime.
  • A single gap in this chain or the possibility of an alternative explanation entitles the accused to the benefit of doubt.
  • Referencing Sharad Birdhichand Sarda vs. State of Maharashtra (1984), the Court underscored that circumstantial evidence must:
    • Be cogently and firmly established.
    • Exclude every other hypothesis except that of the guilt of the accused.

The Court found that the chain of evidence in this case was incomplete and failed to meet the standard required for a conviction based on circumstantial evidence.

Poisoning by Aluminum Phosphide

The Court examined the prosecution’s claim that the deceased was poisoned using aluminum phosphide. Scholarly literature and previous case law (Jaipal vs. State of Haryana, 2003) were reviewed, highlighting the substance’s pungent garlic-like odour, which makes it difficult to administer deceitfully. This aspect raised doubts about the prosecution’s theory.

Disparity in Treatment of Accused

The Court questioned the High Court’s rationale for acquitting Rani Kaur while convicting Darshan Singh, as both were charged with acting in furtherance of common intention under Section 34 IPC. The inconsistent findings further weakened the prosecution’s case.

Decision in Darshan Singh v State of Punjab

The Supreme Court allowed the appeal and set aside the conviction of Darshan Singh. The Court held:

  1. The omissions and contradictions in the prosecution’s evidence created reasonable doubt about the appellant’s guilt.
  2. A statement under Section 313 CrPC cannot serve as the sole basis for conviction.
  3. The circumstantial evidence presented failed to meet the requisite standard, leaving gaps in the chain of events.
  4. The High Court’s selective acquittal of one accused undermined the coherence of the prosecution’s case.

Conclusion

Darshan Singh v State of Punjab case underscores the judiciary’s commitment to safeguarding the principles of fair trial and the rights of the accused. It reiterates the importance of:

  1. Strict adherence to evidentiary standards in criminal cases.
  2. The need for a robust and complete chain of evidence in circumstantial cases.
  3. Ensuring equitable treatment of co-accused under the law.

The judgement also highlights the limitations of relying on procedural statements (Section 313 CrPC) to establish guilt, reinforcing that substantive, corroborated evidence remains paramount in securing convictions.


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