This appeal challenged the concurrent judgments of the High Court and Trial Court which convicted the appellant under Sections 302, 201, and 377 of the Indian Penal Code based on circumstantial evidence, a “last seen” theory, an extra-judicial confession, and subsequent disclosures. The Supreme Court set aside the conviction, ruling that the prosecution failed to establish a complete and unbroken chain of circumstances connecting the accused to the crime, burdened as the case was by major discrepancies, fabricated timelines, and an unreliable extra-judicial confession.
- Flawed Circumstantial Chain: The prosecution failed to conclusively prove the “last seen” theory, as primary witnesses did not support it in their examination-in-chief, and vital evidence like a generic snack packet lacked any connection to the appellant.
- Inadmissible and Unreliable Confession: The alleged extra-judicial confession made to a village Sarpanch closely tied to the police was found to be highly improbable and uncorroborated, serving as a weak piece of evidence that could not form the sole basis for conviction.
- Contradictory Timelines: Material contradictions—such as witnesses testifying that the police already had the accused in custody on March 12, 2007—completely demolished the official narrative of an extra-judicial confession and disclosure statement recorded days later on March 14, 2007.
- Absence of Forensic Matching: Although semen was found on the appellant’s underwear and the victim’s rectal swab, no DNA profiling was conducted to link the two, and courts improperly shifted the burden of proof onto the accused.
- Final Disposition: The Supreme Court allowed the appeal by extending the benefit of the doubt to the appellant, setting aside the lower court judgments, and reaffirming his immediate release after over 16 years of incarceration
2026 INSC 945
Sahab Singh alias Sat Pal v. State of Haryana (D.O.J.02.09.2026)
