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2025 Supreme(SC) 1208

MANOJ MISRA, SANDEEP MEHTA
Shanti Devi – Appellant
Versus
State of Haryana – Respondent


Advocates appeared:
For the Appellant(s) : Dr. Nirmal Chopra, AOR Ms. Aaina Verma, Adv. Mr. Amit Kumar, Adv.
For the Respondent(s): Mr. Vishal Khattar, A.A.G. Mr. Akshay Amritanshu, AOR Ms. Drishti Rawal, Adv. Ms. Drishti Saraf, Adv. Mr. Sarthak Shrivastava, Adv. Mr. Mayur Goyal, Adv.

Judgement Key Points

Certainly. Based on the provided legal document, here are the key legal points:

  1. The case was primarily based on circumstantial evidence, and the prosecution was required to establish a complete chain of incriminating circumstances beyond all reasonable doubt. The court emphasized that the evidence must fully prove the circumstances and that these should be consistent only with the guilt of the accused, excluding all other hypotheses (!) (!) .

  2. The evidence regarding motive was found to be unsubstantiated. The court scrutinized the alleged motives, such as illegal occupation of property and illicit relationships, and concluded that they were either contradicted by the evidence or not sufficiently proved. The absence of credible motive weakens the prosecution's case (!) (!) (!) (!) (!) (!) (!) .

  3. The admissibility and evidentiary value of confessional statements made outside the presence of a police officer were critically examined. The court held that such confessions, recorded in the presence of police, have very weak evidentiary value unless they lead to the discovery of incriminating facts as per legal provisions. In this case, the confessions were deemed inadmissible and unreliable, especially since they were made in police presence and were not supported by independent evidence (!) (!) (!) (!) .

  4. The court found that the alleged recoveries of weapons and incriminating articles were fabricated or planted, especially given the negative forensic reports indicating the absence of human blood or other incriminating evidence on the recovered items. This undermined the credibility of the prosecution’s case concerning physical evidence (!) (!) (!) (!) (!) .

  5. Witnesses who claimed to have seen the accused with the victim or to have received confessions from them were considered unreliable, partly due to contradictions, delays in recording statements, and lack of prior connection with the accused. The court viewed these testimonies as planted or untrustworthy (!) (!) (!) .

  6. The court highlighted that the entire case was built on flimsy or false evidence, and the reliance on such evidence was misplaced. The negative forensic findings and the inconsistencies in witness testimonies led to the conclusion that the prosecution failed to establish the guilt of the accused beyond a reasonable doubt (!) (!) .

  7. As a result, the court acquitted the accused of all charges, emphasizing that where the prosecution evidence is unreliable, contradictory, or insufficient, the benefit of doubt should be extended to the accused, including those who did not appeal. The court also noted that the benefit of this judgment should be granted to other accused who did not pursue appeals, especially when the evidence against them is similarly unconvincing (!) (!) (!) .

  8. The court reaffirmed the principle that confessional statements and extrajudicial confessions require careful scrutiny and should be supported by independent evidence and corroboration to be used as a basis for conviction (!) (!) .

In summary, the judgment underscores the importance of establishing a complete and credible chain of evidence in cases based on circumstantial evidence, the limited evidentiary value of confessions recorded in police presence, and the necessity of reliable physical evidence to sustain a conviction. When these standards are not met, the benefit of doubt must favor the accused, leading to their acquittal.


Table of Content
1. summary of trial and appeals regarding the accused's conviction. (Para 1 , 2 , 3)
2. details surrounding the murder and identification of the victim. (Para 4 , 5 , 6)
3. discussion of prosecution's burden of proof and evidentiary standards. (Para 10 , 11)
4. analysis of motives for murder presented by the prosecution. (Para 12 , 13)
5. examination of witness statements and contradictions in testimony. (Para 14 , 15 , 16 , 17 , 18)
6. evaluation of confessions and the admissibility under law. (Para 20 , 21 , 22)
7. conclusions leading to the acquittal of the accused. (Para 30 , 31 , 32 , 35 , 36 , 37)

JUDGMENT :

1. The accused-appellant Shanti Devi, Rajbir (accused No. 2) and Veena (accused No.3) faced trial in the Court of Additional Sessions Judge, Hisar1[Hereinafter, referred to as the ‘trial Court’.] for the offences punishable under Section 302 read with Section 34 of the INDIAN PENAL CODE , 18602[Hereinafter, referred to as the ‘IPC’.] and Section 201 read with Section 34 IPC.

3. The accused-appellant Shanti Devi and Rajbir (accused No.2) preferred CRA-D-178-DB of 2003 before the High Court of Punjab and Haryana3[Hereinafter, referred to as ‘High Court.’] for ass

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