The Supreme Court acquitted the accused, ruling the prosecution failed to establish a complete chain of circumstantial evidence. Key scientific evidence, including DNA reports, was deemed inadmissible due to an unproven chain of custody and procedural flaws. The Court emphasized that suspicion, however strong, cannot substitute for proof beyond reasonable doubt.
Facts Of The Case:
On the evening of September 4, 2012, a 12-year-old girl left her home to answer the call of nature and did not return. Her parents initiated a search throughout the night. The next morning, her denuded body was discovered in a paddy field belonging to Harikrishna Sharma. Her personal belongings, including her slippers, water canister, and underwear, were found scattered in an adjacent field cultivated by the accused, Putai. The police registered an FIR for rape and murder. The investigation relied heavily on circumstantial evidence, including the recovery of the victim’s articles from Putai’s field and the alleged suspicious conduct of the accused. A sniffer dog was also used, which purportedly led the police to the house of the second accused, Dileep, after smelling a comb found at the scene. The prosecution’s case included DNA reports, but the first was inconclusive and a supplementary report was introduced later. The trial court convicted both accused, sentencing Putai to death and Dileep to life imprisonment, which the High Court later confirmed. The case ultimately reached the Supreme Court on appeal.
Procedural History:
The case originated with the conviction of the accused-appellants by the Additional Sessions Judge, Lucknow, on March 14 and 19, 2014, sentencing Putai to death and Dileep to life imprisonment for offences including rape and murder. The trial court made a death reference to the Allahabad High Court for confirmation. Simultaneously, the convicts filed appeals challenging their conviction. In a common judgment dated October 11, 2018, the High Court dismissed the appeals and confirmed the death sentence for Putai. The accused-appellants then approached the Supreme Court by filing special leave petitions, which were heard together, leading to the present judgment of acquittal on August 26, 2025.
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Court Observation:
The Supreme Court made several critical observations leading to the acquittal. It found the prosecution’s circumstantial evidence woefully inadequate, failing to form an unbroken chain of incriminating circumstances. The Court heavily criticized the investigation, noting the DNA evidence was rendered inadmissible due to a complete failure to prove the chain of custody of forensic samples, with no documentation for the collection, sealing, or transmission of blood samples and vaginal swabs. The supplementary DNA report was deemed inconsequential as it was never put to the accused under Section 313 CrPC. The recovery of the victim’s belongings from an open, accessible field was held to be insufficient to conclusively prove guilt, and the alleged “suspicious conduct” of the accused was ruled to be natural and non-incriminating. The Court concluded that the prosecution relied on suspicion rather than proof beyond a reasonable doubt.
Final Decision & Judgement:
The Supreme Court allowed the appeals and acquitted the accused-appellants, Putai and Dileep. The Court quashed and set aside the impugned judgment of the High Court as well as the conviction and sentences awarded by the trial court. Holding that the prosecution failed to prove its case beyond a reasonable doubt, the Court extended the benefit of the doubt to the appellants. It directed that they be released from custody forthwith, provided they are not required in any other case.
Case Details:
Case Title: Putai & Anr. vs State of Uttar Pradesh Citation: 2025 INSC 1042 Criminal Appeal No(s).: Criminal Appeal No. 154 of 2025 Date of Judgement: August 26, 2025 Judges/Justice Name: Justice Vikram Nath & Justice Sanjay Karol, and Justice Sandeep Mehta
Download The Judgement Here