“If there is a snap in the chain of circumstances, the accused is entitled to benefit of doubt:” Supreme Court

While hearing the Darshan Singh vs. The State of Punjab case on January 04, 2024, the Supreme Court (SC) of India observed that the prosecution could not seek to prove a fact during a trial that had not been stated to the police during the investigation. The bench further said “The evidence of that witness regarding the said improved fact is of no significance.” Moreover, the SC expressed dissatisfaction with the Punjab & Haryana High Court’s findings as it convicted the appellant (accused) for murder but the other co-accused were acquitted. It added, “According to us, if the evidence of PW 3 and PW 4 was not sufficient to prove presence of Rani Kaur at the appellant’s house, as a natural corollary, such evidence cannot be relied on to conclude that the appellant was present in the house. The manner in which the High Court has sought to distinguish the case of the appellant from Rani Kaur is perverse and does not seem to impress us.” The matter was heard by a three-judge bench comprising Justice P.S. Narasimha, Justice Aravind Kumar, and Justice B.R. Gavai. The question addressed by the bench while hearing the case was “Whether the prosecution had proved beyond reasonable doubt, the entire chain of circumstances, not leaving any link missing for the appellant to escape from the clutches of law?”

In this case, the deceased (Amrik Kaur) was married to the appellant (Darshan Singh). The prosecution alleges that their marital relationship was strained owing largely to the fact that the appellant had developed an illicit partnership with Rani Kaur (A2). With the motive of eliminating the deceased, Darshan Singh and Rani Kaur administered poison and intentionally caused the death of the deceased. The matter was initially heard by the Trial Court. It convicted both the accused persons for the offence under Section 302 r/w Section 34 and sentenced them to undergo imprisonment for life. Moreover, it was found that the appellant had a strong motive to commit the murder of his wife. The High Court agreed with the findings of the Trial Court. The appellant approached the Supreme Court against the decision of the HC.

The Supreme Court allowed the appeal and said that “This Court has held that the standard of proof to be met by an accused in support of the defence taken by him under Section 313 of Code of Criminal Procedure is not beyond all reasonable doubt, as such, a burden lies on the prosecution to prove the charge. The accused has merely to create a doubt and it is for the prosecution then to establish beyond reasonable doubt that no benefit can flow from the same to the accused.” Furthermore, the SC said, “When the conviction is to be based on circumstantial evidence solely, then there should not be any snap in the chain of circumstances. If there is a snap in the chain, the accused is entitled to benefit of doubt. If some of the circumstances in the chain can be explained by any other reasonable hypothesis, then also the accused is entitled to the benefit of doubt.”