Summary and Analysis of Neelam Kumari vs State of Himachal Pradesh

1. Heading of the Judgment
Neelam Kumari vs. State of Himachal Pradesh (2025 INSC 1013)
Supreme Court Acquits Mother Accused of Murdering Her Infant Son Due to Lack of Conclusive Evidence

Citation:
Neelam Kumari v. State of Himachal Pradesh, (2025) INSC 1013, Criminal Appeal No. 582 of 2013 (Supreme Court of India).

2. Related Laws and Sections

• Indian Penal Code, 1860 (IPC):
  Section 302: Punishment for murder.

• Code of Criminal Procedure, 1973 (CrPC):
  Section 313: Power to examine the accused.

• Legal Doctrines:
  Principles governing extra-judicial confessions.
  Golden principles for evaluating circumstantial evidence (from Hanumant v. State of MP and Sharad Birdhichand Sarda v. State of Maharashtra).

3. Basic Judgment Details

• Parties:
  Appellant: Neelam Kumari
  Respondent: State of Himachal Pradesh

• Courts Involved:
  Trial Court: Convicted and sentenced the appellant to life imprisonment.
  High Court: Upheld the conviction.
  Supreme Court: Heard the appeal and acquitted the appellant.

• Key Dates:
  Incident: 8–9 December 2006
  Trial Court Judgment: 20 July 2007
  High Court Judgment: 11 December 2009
  Supreme Court Judgment: 20 August 2025

4. Explanation of the Judgment

The Supreme Court, in Neelam Kumari vs. State of Himachal Pradesh, overturned the conviction of the appellant for the murder of her infant son. The Court found that the prosecution failed to prove guilt beyond reasonable doubt due to inconsistencies in evidence, unreliable extra-judicial confessions, and lack of motive.

Key Reasons for Acquittal:

1. Weakness of Extra-Judicial Confessions:
   The prosecution relied on alleged confessions made by the appellant to her husband (PW-1), a ward member (PW-3), the village Pradhan (PW-4), and another woman (PW-5). The Supreme Court reiterated that extra-judicial confessions are inherently weak evidence and require strong corroboration. The appellant denied these confessions during her examination under Section 313 of the CrPC, and the prosecution failed to examine independent witnesses (like Sita Devi) who could have verified the claims.

2. Insufficient Circumstantial Evidence:
   The Court applied the five "golden principles" for circumstantial evidence:
   The circumstances must be fully established.
   They must point only to the guilt of the accused.
   They must be conclusive and exclude every other hypothesis.
   The chain of evidence must be complete and consistent with guilt.
   The prosecution could not establish a complete chain. The appellant’s whereabouts during the critical period were unclear, and the timeline between the alleged strangulation and medical examination (8–10 hours) allowed for other possibilities.

3. Unreliable Forensic Evidence:
   The alleged murder weapon—a green dupatta—was never shown to the doctor who conducted the autopsy. The forensic report found blood and skin tissues on the dupatta, but there was no proof these belonged to the deceased. The Court noted that such evidence was ambiguous and inconclusive.

4. Lack of Motive:
   The prosecution claimed the appellant killed her son because she resented her husband’s visits to his first wife’s village. The Court found this motive illogical, as the appellant had voluntarily visited the same village with her child just a day earlier. The Court emphasized that the absence of a strong motive weighs in favor of the accused in circumstantial evidence cases.

5. Conduct of the Appellant:
   The appellant’s behavior—seeking medical help for the child immediately after finding him unresponsive—was inconsistent with guilt. The Court found it unlikely that a mother would strangle her child and then urgently try to save him.

Conclusion:
The Supreme Court held that the prosecution failed to meet the standard of proof beyond reasonable doubt. The conviction under Section 302 of the IPC was set aside, and the appellant was acquitted. Since she was already on bail, her bail bonds were discharged.