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Supreme Court of India 2017-06-09 allowed

Satish Nirankari vs State of Rajasthan

Bench: 2 — A.K. Sikri

In Brief

Satish Nirankari was convicted of murdering Pooja Bhatnagar, a 23-year-old MBA student with whom he was in love. Pooja's parents opposed their inter-caste marriage. On 1 November 1995, both consumed copper sulphate poison and Pooja was found hanged. The Supreme Court acquitted Nirankari, holding that the prosecution failed to prove guilt beyond reasonable doubt. The suicide note allegedly written by Pooja, initially confirmed by the investigating officer as in her handwriting, was credibly established as genuine. The appellant's conduct—raising alarm, calling for help, and ensuring hospital treatment—contradicted murderous intent. Critical gaps included absence of proof of poison administration and no forensic analysis of the alleged murder weapon. The cumulative circumstantial evidence was insufficient to exclude the hypothesis of a suicide pact.

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Criminal Law Circumstantial Evidence Burden of Proof Homicide Suicide Evidence—Handwriting and Expert Opinion Medical Jurisprudence Credibility of Witnesses Procedure under Section 313 CrPC

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