RANDEEP SINGH @ RANA & ANR. versus STATE OF HARYANA & ORS.

RANDEEP SINGH @ RANA & ANR. versus STATE OF HARYANA & ORS.

The convictions could not be sustained because key evidence was legally inadmissible or unreliable: the eyewitness testimony (PW-26) contained material omissions and identification was doubtful without a test parade; the CD of CCTV footage lacked the mandatory Section 65B certificate and supporting verification; confessional material recorded by police was inadmissible beyond the narrow scope of Section 27 and inadmissible statements were placed on record; consequently the chain of circumstantial evidence was incomplete and recovery alone was insufficient to prove guilt beyond reasonable doubt, requiring acquittal of the appellants.

Parties
Appellants: Randeep Singh @ Rana & Anr.; Respondents: State of Haryana & Ors.
Jurisdiction
India
Judgment Date
22 November 2024
Procedural Posture
Criminal Appeal / Supreme Court Judgment (final Disposal)
Outcome
Appeal allowed; convictions and sentences quashed and set aside; appellants acquitted and to be released if in custody unless required in connection with any other offence.
Legal Topics
Abduction, Murder, Criminal Conspiracy, Proof Beyond Reasonable Doubt, Identification and Test Identification Parade, CCTV Evidence and Section 65 B, Admissibility of Confessions to Police, Evidence of Recovery, Circumstantial Evidence
Criminal Law Evidence Criminal Procedure Abduction Murder Criminal Conspiracy Proof Beyond Reasonable Doubt Identification and Test Identification Parade +4 more

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Parties

Randeep Singh @ Rana & Anr.

Appellants

State of Haryana & Ors.

Respondents

Procedural Posture

Criminal Appeal / Supreme Court Judgment (final Disposal)

Legal Issues

  1. 1 Whether conviction under Sections 364, 302, 120-B and 201 IPC was justified on the evidence produced
  2. 2 Admissibility of CD of CCTV footage in absence of certificate under Section 65B Evidence Act
  3. 3 Admissibility and scope of confessions/statements made to police while in custody (ss.25-27 Evidence Act)

Ratio Decidendi

The convictions could not be sustained because key evidence was legally inadmissible or unreliable: the eyewitness testimony (PW-26) contained material omissions and identification was doubtful without a test parade; the CD of CCTV footage lacked the mandatory Section 65B certificate and supporting verification; confessional material recorded by police was inadmissible beyond the narrow scope of Section 27 and inadmissible statements were placed on record; consequently the chain of circumstantial evidence was incomplete and recovery alone was insufficient to prove guilt beyond reasonable doubt, requiring acquittal of the appellants.

Court Disposition

Appeal allowed; convictions and sentences quashed and set aside; appellants acquitted and to be released if in custody unless required in connection with any other offence.

Orders

  • Quash and set aside the judgments dated 14 February 2017 and 17 February 2017 passed by the Additional Sessions Judge, Ambala in Sessions Case No. 16 of 2013.
  • Quash and set aside the impugned judgment dated 10 February 2020 passed by the High Court of Punjab & Haryana at Chandigarh in Criminal Appeal Nos. D-335-DB and D-398-DB of 2017 (O&M).