The Supreme Court upheld the High Court’s acquittal, emphasizing the prosecution’s failure to prove guilt beyond reasonable doubt. The evidence presented, including motive, last seen theory, and recoveries, was found unreliable, inconclusive, and legally inadmissible. The Court reiterated that appellate interference in an acquittal is unwarranted unless the judgment is perverse or based on a misreading of evidence.
Facts Of The Case:
The case originated from the murder of Shri Suresh Sharma, whose body was discovered on January 23, 2006, with his hands tied and visible signs of strangulation. The prosecution’s case was that the respondents, Bhanwar Singh, Hemlata, and Narpat Choudhary, conspired to kill the deceased due to various motives. It was alleged that Hemlata and her husband Narpat were perturbed by the deceased’s frequent visits to their house, while Bhanwar Singh held a grudge over a land dispute in which the deceased had supported the other party. The prosecution claimed the accused hired contract killers from Uttar Pradesh, lured the victim to Hemlata’s residence on January 22, 2006, where he was strangled, and then transported his body in a Maruti van to abandon it. The trial court convicted the respondents, but the High Court acquitted them, citing insufficient evidence and infirmities in the prosecution’s case. This acquittal was challenged by the State of Rajasthan before the Supreme Court.
Procedural History:
The procedural history of this case commenced with the conviction of the respondents by the Learned Additional Sessions Judge (Fast Track) No.2, Jodhpur, vide judgment dated January 10, 2008, for offenses including murder and conspiracy. Aggrieved by this conviction, the respondents filed appeals under Section 374(2) of the Code of Criminal Procedure, 1973, before the Division Bench of the Rajasthan High Court at Jodhpur. The High Court, vide its common judgment dated December 14, 2011, allowed the appeals, set aside the conviction, and acquitted all the respondents. Challenging this acquittal, the State of Rajasthan filed the present criminal appeals before the Supreme Court of India, which, after examining the evidence, dismissed the State’s appeals and upheld the acquittal vide its judgment dated September 26, 2025.
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Court Observation:
The Supreme Court meticulously re-appreciated the evidence and concurred with the High Court’s observations, finding the prosecution’s case riddled with fatal infirmities. It noted the complete failure to prove motive, as the testimonies of key witnesses were either unreliable, improved versions of their previous statements, or outright denied any ill-will. The “last seen” evidence was discarded due to the witnesses’ highly unnatural and suspicious conduct in delaying their disclosure to the police for over a month. The Court further held that various recoveries, including a blood-stained chunni and a Maruti van, were inconsequential as the blood group was not matched to the deceased and the recoveries were from places accessible to all. Crucially, electronic evidence like call detail records was deemed inadmissible for want of a certificate under Section 65-B of the Indian Evidence Act. The Court concluded that the prosecution failed to establish a chain of circumstantial evidence and that the acquittal by the High Court was a plausible view based on a proper appreciation of evidence, warranting no interference.
Final Decision & Judgement:
The Supreme Court, in its final judgment, dismissed the appeals filed by the State of Rajasthan and upheld the acquittal of all the respondents—Bhanwar Singh, Hemlata, and Narpat Choudhary. The Court affirmed the decision of the High Court, concluding that the prosecution had failed to prove its case beyond a reasonable doubt. It found the evidence presented, including the theories of motive, last seen, and various recoveries, to be unreliable, inadmissible, or insufficient to form a complete chain of circumstantial evidence pointing unequivocally to the guilt of the accused. Consequently, the acquittal judgment dated December 14, 2011, was maintained, and the respondents were confirmed to be entitled to the benefit of doubt.
Case Details:
Case Title: State of Rajasthan vs. Bhanwar Singh Etc. Etc. Citation: 2025 INSC 1166 Criminal Appeal No(s).: 1954-1956 of 2013 Date of Judgement: September 26, 2025 Judges/Justice Name: Justice Sandeep Mehta and Justice Joymalya Bagchi
Download The Judgement Here