Rajendra Singh vs State of Uttaranchal - Criminal Evidence Case

Criminal Law October 7, 2025

Supreme Court acquits accused due to lack of proper identification and forensic evidence - establishes strict standards for circumstantial evidence

❓ QUESTION

If someone is accused of a crime, but no witness can clearly identify them in court, and the recovered weapons are not scientifically linked to the crime, can they be convicted based on circumstantial evidence?

✅ ANSWER

No, a conviction cannot stand. The Supreme Court has firmly established that the identity of the accused as the actual perpetrator must be proven beyond a reasonable doubt. If the evidence fails to conclusively connect the accused to the crime, they must be given the benefit of the doubt.
In this case, the Court acquitted the accused because:

  1. The sole eyewitness who saw the attack could not name or identify the assailants.
  2. The other witnesses who claimed to identify the accused were found to be unreliable "chance witnesses" whose presence at the scene was doubtful.
  3. The recovered weapons were not forensically tested to prove they were used in the crime.

🧩 UNDERSTANDING THE LEGAL PRINCIPLES

⚖️ What the Supreme Court Has Clarified

1️⃣ The Identity of the Accused Must Be Proven, Not Presumed

The Court emphasized that establishing the identity of the accused as the person who committed the crime is the foundation of a criminal case.

  • The Legal Principle: The prosecution must lead cogent (convincing and compelling) evidence to prove that the specific individuals on trial are the ones who committed the offence. Motive alone is not enough.
  • In This Case: While the appellants had a prior quarrel with the victim's family, providing a possible motive, the Court stated this "by itself would not be sufficient to rope in the appellants unless their involvement in the offence is established by cogent evidence." The core issue was whether they were the actual assailants.

2️⃣ An Eyewitness Who Cannot Identify the Accused is of No Value

The Court drew a critical distinction between witnessing an event and identifying the perpetrators.

  • The Legal Principle: A witness may truthfully see a crime occur but be unable to identify the criminals. If a witness does not know the accused by name and no identification parade is held, their testimony cannot legally connect the accused to the crime.
  • In This Case: The key eyewitness, Amarjeet Kaur (PW-7), saw the murder happen in her own house. However, she clearly stated she "did not know the name of the accused persons." The police never held an identification parade for her to point out the attackers from a lineup. Therefore, her otherwise credible testimony could not prove that the appellants were the culprits.

3️⃣ The Testimony of a "Chance Witness" is Viewed with Great Caution

The Court reinforced a well-established legal principle regarding the reliability of witnesses who have no compelling reason to be at the scene of the crime.

  • The Legal Principle: A "chance witness" is one whose presence at the place of incident appears to be accidental or coincidental. Courts must scrutinize their evidence closely and they must adequately explain their presence. If their presence is doubtful, their testimony is discarded.
  • In This Case: The victim's father (PW-1) and another witness (PW-2) claimed to have seen the accused chasing the victim. The Court found their presence to be unnatural and doubtful. PW-1 took a route that was not on his way home, and PW-2 was simply going to buy soap. The Court held they were "chance witnesses" and their evidence could not be relied upon to identify the assailants.

4️⃣ Recovery of Weapons is Meaningless Without Forensic Corroboration

The Court explained the limited value of recovering weapons based on an accused's statement.

  • The Legal Principle: Under Sections 25, 26, and 27 of the Indian Evidence Act, a confession made to the police is not admissible. Only the part of a statement that leads directly to the discovery of a fact (like a weapon) is admissible.
  • The Critical Distinction: The police can prove that "the accused said, 'I hid the sword in the field,' and we found it there." They cannot prove that the accused said, "I hid the sword which I used to kill the victim." The latter part is an inadmissible confession.
  • In This Case: The weapons were recovered but never sent for forensic analysis to match the blood on them with the deceased. Without this scientific link, the recovery only proves that the accused knew where the weapons were hidden, not that they were used in the murder.

🧭 YOUR ACTION PLAN: UNDERSTANDING EVIDENCE IN CRIMINAL TRIALS

📝 If You Are a Victim or a Witness

✅ Step 1: Focus on Identification

  • If you witness a crime, pay close attention to the faces and identifiable features of the perpetrators.
  • If you do not know the accused, insist that the police hold a proper Test Identification Parade (TIP) while the faces are fresh in your memory. This is a critical step to legally connect the accused to the crime.

✅ Step 2: Ensure Forensic Evidence is Collected

  • If possible, note if the culprits left behind any evidence (weapons, objects, etc.).
  • Encourage the investigating agency to promptly send all physical evidence for forensic examination (like FSL) to establish a scientific link to the crime.

📝 If You Are Accused of a Crime

✅ Step 1: Scrutinize the Evidence of Identity

  • Your lawyer should rigorously cross-examine eyewitnesses on whether they could truly see and identify you.
  • Challenge the testimony of "chance witnesses" by highlighting the improbability of their presence and the lack of a credible explanation for it.

✅ Step 2: Understand the Law on Confessions and Recoveries

  • Know that any confession you make to the police cannot be used against you in court.
  • If weapons or objects are recovered based on your information, the prosecution can only prove that you led them to the item. They cannot use your statement that you used that item in a crime. Your lawyer can object to any such confession being presented as evidence.

✅ Step 3: Demand Scientific Corroboration

  • If the prosecution relies on recovered weapons, your lawyer must demand the Forensic Science Lab (FSL) report.
  • If no report exists, or if the report does not link the weapon to the crime, argue that the recovery is meaningless and does not prove your guilt.

⚖️ KEY LEGAL PROVISIONS EXPLAINED

💡 CORE TAKEAWAY FROM THE SUPREME COURT

"The gap between suspicion and proof must be bridged by clear, cogent, and credible evidence. In the absence of such evidence, the benefit of doubt must invariably go to the accused."

This judgment is a powerful reaffirmation of the fundamental right to a fair trial. It reminds the police and prosecutors that their duty is to build a watertight case based on reliable evidence, not to secure a conviction based on doubt, motive, or procedural lapses. For the common citizen, it underscores that every person is innocent until proven guilty, and the prosecution must cross a high bar of proof before a person's liberty can be taken away.

⚠️ DISCLAIMER: This content is for informational purposes only and does not constitute legal advice. The outcome of any case depends on its specific facts. Consult a qualified criminal lawyer for your specific situation.