2026 Supreme(All) 453

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD LUCKNOW
SINGH CHAUHAN, ABDHESH KUMAR CHAUDHARY, JJ.
Sanjay Rai – Appellant
Versus
State of U.P. – Respondent
CRIMINAL APPEAL No. - 475, 671, 672, 673 of 2020
Decided on : 05-06-2026

In a circumstantial evidence case, a conviction cannot be sustained based solely on custodial confessions or case diary entries, as these are not substantive legal evidence. The prosecution must establish a complete, unbreakable chain of events through unimpeachable, admissible evidence that excludes any reasonable hypothesis of innocence.

Headnote:(A) Code of Criminal Procedure, 1973 - Sections 161, 162, 172, 313, 374(2) - Indian Evidence Act, 1872 - Sections 25, 26, 27, 30 - Indian Penal Code - Sections 302, 120-B, 34, 449 - Murder - Circumstantial evidence - Requirements for conviction - Held, court must ensure chain of evidence is complete and establishes guilt to the exclusion of any other hypothesis - In absence of independent corroboration or substantial proof, conviction cannot be based on police-recorded confessional statements or case diary entries used as substantive evidence. (Paras 72, 84, 111)

(B) Evidence - Confession - Admissibility - Confessional statements made by accused while in police custody are hit by strict prohibitions under the law - Such statements cannot form the basis of conviction or act as a substitute for substantive evidence. (Paras 82, 85, 116)

(C) Evidence - Discovery - Section 27 of Evidence Act - Requirement of due process - Discovery evidence requires independent attestation and clear tracing to the authorship of concealment, failing which recovery remains suspect. (Paras 94, 96)

Facts of the case:
Multiple persons were convicted for conspiracy and commission of murder. The prosecution alleged that the crime was premeditated, involving hired assailants and logistical support, proven primarily through custodial confessions, recoveries of weapons/vehicles, and alleged motive. During trial, key eyewitnesses either did not identify the accused or turned hostile. The prosecution relied heavily on case diary records and confessional statements to secure convictions.

Findings of Court:
The trial court's judgment was based on evidence of poor quality, including inadmissible custodial confessions and recoveries lacking independent witnesses. The forensic report failed to link recovered items to the specific crime definitively. Evidence of conspiracy was absent, and the prosecution failed to prove an unbroken chain of circumstances.

Issues: The primary issues concerned the admissibility of custodial confessions, the reliance on police internal diaries as substantive evidence, and whether the established circumstantial evidence was sufficient to exclude the hypothesis of innocence.

Ratio Decidendi: Conviction in a circumstantial case requires a chain of evidence so complete that it leaves no reasonable ground for any other conclusion. Custodial confessions and case diaries are not substantive pieces of evidence; investigative material that fails to meet threshold requirements of law cannot support a conviction. The burden remains on the prosecution to prove its case beyond reasonable doubt through legally admissible evidence.

Result: Appeals allowed. Conviction and sentence set aside; appellants acquitted.