SHANTI DEVI versus STATE OF HARYANA

SHANTI DEVI versus STATE OF HARYANA

The prosecution failed to establish a complete and cogent chain of incriminating circumstances: the alleged motive was unsubstantiated and contradictory, the last-seen-together and extra-judicial confession evidence were unreliable and likely fabricated, the recoveries were doubtful and rendered inconsequential by a negative FSL/serology report; therefore convictions and sentences under Sections 302/34 and 201/34 IPC could not be sustained and the accused (appellant and non-appealing co-accused) were to be acquitted.

Parties
Appellant: Shanti Devi; Respondent: State of Haryana; Co Accused: Rajbir; Co Accused (deceased): Veena
Jurisdiction
India
Judgment Date
06 August 2025
Procedural Posture
Criminal Appeal (criminal Appeal No. 2861 of 2025) / Appeal by Special Leave to the Supreme Court; Judgment on Appeal
Outcome
Appeal allowed; convictions and sentences quashed and set aside; appellant acquitted; benefit extended to non-appealing co-accused (Rajbir) who is acquitted; appeal of Veena abated on her death.
Legal Topics
Murder, Illegal Occupation, Chain of Incriminating Circumstances, Appellate Jurisdiction, Testimony of the Witnesses, Last Seen Together Theory, Extra Judicial Confession Theory, Theory of Motive, Negative FSL Report, Incriminating Recoveries, Recoveries, Benefit to the Non Appealing Accused
Penal Code, 1860 Evidence Act, 1872 Code of Criminal Procedure, 1973 Murder Illegal Occupation Chain of Incriminating Circumstances Appellate Jurisdiction Testimony of the Witnesses +7 more

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Parties

Shanti Devi

Appellant

State of Haryana

Respondent

Rajbir

Co Accused

Veena

Co Accused (deceased)

Procedural Posture

Criminal Appeal (criminal Appeal No. 2861 of 2025) / Appeal by Special Leave to the Supreme Court; Judgment on Appeal

Legal Issues

  1. 1 Whether the evidence was sufficient to convict for offences under Sections 302/34 and 201/34 IPC
  2. 2 Whether circumstantial evidence including last-seen-together and extra-judicial confession established guilt beyond reasonable doubt
  3. 3 Whether the recoveries and FSL/serological reports supported the prosecution case

Ratio Decidendi

The prosecution failed to establish a complete and cogent chain of incriminating circumstances: the alleged motive was unsubstantiated and contradictory, the last-seen-together and extra-judicial confession evidence were unreliable and likely fabricated, the recoveries were doubtful and rendered inconsequential by a negative FSL/serology report; therefore convictions and sentences under Sections 302/34 and 201/34 IPC could not be sustained and the accused (appellant and non-appealing co-accused) were to be acquitted.

Court Disposition

Appeal allowed; convictions and sentences quashed and set aside; appellant acquitted; benefit extended to non-appealing co-accused (Rajbir) who is acquitted; appeal of Veena abated on her death.

Orders

  • Impugned judgment of the High Court dated 24.05.2024 quashed and set aside
  • Judgment of the trial Court dated 14.01.2003 quashed and set aside