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Supreme Court of India 2024-01-04 allowed

DARSHAN SINGH vs STATE OF PUNJAB

Bench: 3 — B. R. Gavai, Pamidighantam Sri Narasimha, Aravind Kumar

In Brief

Darshan Singh was convicted along with his co-accused Rani Kaur for poisoning and murdering his wife Amrik Kaur on 19 May 1999. The High Court upheld his conviction but acquitted Rani Kaur. The Supreme Court allowed his appeal. The prosecution's case rested solely on circumstantial evidence. The critical issue was whether the appellant was present in his house when the poisoning occurred. The Court found that the key witnesses (PW-3 and PW-4) made significant omissions in police statements that they only added later during trial—omissions that could not be attributed to illiteracy. The characteristic features of aluminium phosphide (pungent odour, absence of scuffle marks) raised doubt about whether the poison could have been administered deceitfully or forcefully. The Court held that since identical evidence was insufficient to prove the co-accused's presence (for whom benefit of doubt was granted), it could not be used to prove the appellant's presence. With a key circumstance doubtful, the chain of circumstantial evidence contained a fatal gap, entitling the appellant to benefit of doubt.

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Criminal Law Circumstantial Evidence Murder Poisoning Alibi and Alternative Hypothesis Witness Credibility Omissions in Police Statement Indian Evidence Act

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