Legal Review and Analysis of Rajendra Singh and Ors vs State of Uttaranchal 2025 INSC 1193

1. Heading of the Judgment

Rajendra Singh and Ors. vs State of Uttaranchal etc., Criminal Appeal Nos. 476-477 of 2013, Supreme Court of India, decided on October 07, 2025.

Citation: 2025 INSC 1193

2. Related Laws and Sections

This judgment primarily deals with the following legal provisions:

• Indian Penal Code, 1860 (IPC):
  Section 302: Punishment for Murder.
  Section 34: Acts done by several persons in furtherance of common intention.

• Indian Evidence Act, 1872:
  Section 25: Confession to police officer not to be proved.
  Section 26: Confession by accused while in custody of police not to be proved against him.
  Section 27: How much of information received from accused may be proved.

3. Basic Judgment Details

• Parties: Appellants - Rajendra Singh, Bhupender Singh, and Ranjeet Singh (father, son, and son-in-law, respectively). Respondent - The State of Uttaranchal (now Uttarakhand).

• Origin: Appeals before the Supreme Court against the judgment and order dated 02.01.2013 of the High Court of Uttaranchal.

• Background: The appellants were accused of murdering Pushpendra Singh. They were acquitted by the Trial Court, but the High Court reversed this acquittal, convicting them under Section 302 IPC and sentencing them to life imprisonment. The Supreme Court appeal challenges this conviction.

4. Core Legal Principles and Judicial Analysis

The Central Issues:
The Supreme Court focused on two primary questions:

1. Whether the ocular evidence presented by the prosecution reliably established the identity of the appellants as the assailants?

2. Whether the recovery of weapons based on the appellants' disclosure could, by itself, form the basis for conviction?

A. Scrutiny of Ocular Evidence and Witness Reliability
The Court conducted a meticulous analysis of the eyewitness accounts:

• Amarjeet Kaur (PW-7): The Court identified PW-7, the lady of the house where the murder occurred, as the most "trustworthy and natural" witness. She was an independent witness who saw three unknown persons assault the deceased. Crucially, she did not know the names of the assailants and was never asked to identify the appellants in court. No Test Identification Parade (TIP) was conducted. Therefore, her testimony, while establishing the crime, failed to connect the appellants to it.

• Diler Singh (PW-1) - The Father of the Deceased: The Court found the testimony of PW-1 unreliable and full of "striking contradictions" with that of PW-7.
  PW-7 stated that the deceased's father arrived at the scene half an hour after the assailants had left. This directly contradicted PW-1's claim of being an eyewitness who chased the appellants and saw the assault.
  PW-1's claim that he hugged his son's body and his clothes were stained with blood was deemed "unnatural" because he never offered these clothes to the police, who also did not seize them.
  The Court classified PW-1 as a "chance witness" whose presence at the scene was doubtful, as the place he claimed to be at was not on his direct route home.

• Jwala Singh (PW-2): The Court also classified PW-2 as a chance witness. His testimony was contingent on following PW-1. Since PW-1's presence itself was doubtful, PW-2's evidence was also rendered unreliable.

• The Court reiterated a key legal principle: The testimony of a chance witness, whose presence is not satisfactorily explained, must be discarded or treated with great caution.

B. The Admissibility and Value of Weapon Recovery
The Court provided an in-depth interpretation of the law concerning recoveries made based on an accused's statement.

• Sections 25 & 26 of the Evidence Act: The Court reiterated that any confession made to a police officer or while in police custody is inadmissible as evidence.

• Section 27 of the Evidence Act - An Exception: This section is a proviso that allows only "so much of the information" received from an accused in custody as "relates distinctly to the fact thereby discovered" to be proved.

• Critical Legal Distinction: The Court, relying on the landmark precedent Pulukuri Kottaya vs. The King Emperor, 1947 MWN Cr 45, clarified the crucial distinction:
  Admissible Part: The information "I will produce a knife concealed in the roof of my house" is admissible because it leads to the discovery of a fact (the knife).
  Inadmissible Part: The subsequent words "with which I stabbed A" are inadmissible as they constitute a confession and do not relate to the discovery itself.

• Application to the Case: In this case, while the recovery of weapons based on the appellants' disclosure was admissible, any accompanying confession that they used those weapons to commit the crime was not admissible. Furthermore, the prosecution failed to link the recovered weapons to the crime forensically, as no FSL report was produced to prove the blood on the weapons matched the deceased's blood.

C. Interference with an Order of Acquittal
The Court emphasized the settled principle that an Appellate Court should not lightly interfere with an order of acquittal. The High Court can reverse an acquittal only if the Trial Court's findings are "perverse or erroneous." The Supreme Court held that the Trial Court's decision to acquit was based on a reasonable appreciation of evidence, and the High Court "manifestly erred" in reversing it without establishing that the Trial Court's view was perverse.

5. Final Outcome and Directions

The Supreme Court allowed the appeals and set aside the conviction and sentence imposed by the High Court. The operative part of the judgment states:

1. The conviction of the appellants under Section 302 IPC and the sentence of life imprisonment are quashed and set aside.

2. The judgment of the Trial Court, which had acquitted the appellants, is restored.

3. The appellants are acquitted of the alleged offence, granting them the benefit of doubt.

4. As the appellants were on bail, their bail bonds were discharged.

6. MCQs Based on the Judgment

Question 1: In Rajendra Singh vs State of Uttaranchal, the Supreme Court held the testimony of Diler Singh (PW-1) to be unreliable. Which of the following was NOT a reason cited by the Court for this finding?
(a) His testimony was full of striking contradictions with the testimony of Amarjeet Kaur (PW-7).
(b) He was declared hostile by the prosecution during the trial.
(c) His presence at the scene of the crime was doubtful, making him a chance witness.
(d) His conduct of not offering his blood-stained clothes to the police was deemed unnatural.

(b) He was declared hostile by the prosecution during the trial.

Question 2: Regarding the recovery of weapons, the Supreme Court, applying Section 27 of the Indian Evidence Act, ruled that?
(a) The entire statement of the accused leading to the recovery, including the confession of using the weapons, is admissible.
(b) Only the part of the information that relates distinctly to the discovery of the weapons is admissible, not the confession of using them in the crime.
(c) The recovery of weapons is inadmissible as the accused were in police custody.
(d) The recovery is conclusive proof of guilt if the weapons are found to be blood-stained.

(b) Only the part of the information that relates distinctly to the discovery of the weapons is admissible, not the confession of using them in the crime.