Legal Analysis: Pulkit @ Monu v. State of Madhya Pradesh

Citation: 2026 INSC 543
Court: Supreme Court of India
Bench: A Division Bench comprising Justice Manoj Misra and Justice Manomhan
Date of Decision: May 20, 2026
Nature of Judgment: Criminal Appeal under Article 136 of the Constitution of India against the judgment of the Madhya Pradesh High Court at Indore.

Synopsis of the Judgment

The appellant was convicted for criminal conspiracy to commit murder under Section 302 read with Section 120B of the Indian Penal Code, 1860 (IPC). The Trial Court and the High Court affirmed the conviction, relying on circumstantial evidence including alleged motive, a chance witness seeing the appellant with co‑accused, and a disclosure statement with seizure of a mobile phone. The Supreme Court allowed the appeal, holding that the circumstances were not fully established, were not of a conclusive nature, and did not form a complete chain pointing to the guilt of the appellant. The testimony of two key witnesses (PW3 and PW5) was discarded by the High Court as having been obtained under coercion; the chance witness (PW9) did not disclose the content of the alleged conversation; the disclosure statement did not lead to any discovery of fact; and the mobile phone evidence did not show prior contact between the appellant and the perpetrators. The appellant was acquitted.

1. Basic Information of the Judgment

• Case Title: Pulkit @ Monu v. The State of Madhya Pradesh

• Citation: 2026 INSC 543

• Criminal Appeal No.: 1818 of 2022

• Bench: Division Bench (Justice Manoj Misra and Justice Manomhan)

• Date of Decision: May 20, 2026

• Court: Supreme Court of India (Criminal Appellate Jurisdiction)

• Impugned Order: Order dated 25.06.2022 of the Madhya Pradesh High Court at Indore in Criminal Appeal No. 1475 of 2012.

2. Legal Framework

Major Laws and Provisions Involved

• Indian Penal Code, 1860 – Section 302 (murder), Section 120B (criminal conspiracy), Section 34 (common intention – for co‑accused).

• Arms Act, 1959 – Section 25 (possession of arms without licence – for co‑accused).

• Indian Evidence Act, 1872 – Section 27 (discovery of fact in consequence of information from accused), Section 24 (confession caused by inducement, threat or promise – not applicable directly), Section 8 (motive), Section 9 (test identification parade – not applicable).

... Upgrade to a Premium Plan to view the full judgment.