16 July 2025 Criminal Appeals & Suspension of Sentence >> Criminal Law  

In a significant ruling, the Supreme Court of India overturned the conviction and death sentence of an appellant, highlighting major failures in the prosecution's case and investigative procedures. The case, Baljinder Kumar Kala v/s State of Punjab, centered on a criminal appeal against a judgment by the High Court of Punjab and Haryana, which had upheld the conviction and confirmed the death penalty imposed by the Additional Sessions Judge, Kapurthala. The Supreme Court's decision, delivered by a bench including Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta on July 16, 2025, meticulously deconstructed the evidence and witness testimonies, ultimately concluding that the prosecution failed to prove the appellant's guilt beyond a reasonable doubt.

Case Background:

The case involved a horrific incident on November 29, 2013, where four family members—the appellant's wife Seema Rani, his sister-in-law Reena Rani, and their two young children, Sumani Kumari and Harsh—were found dead. Two other family members, Harry and Om Prakash Tari, were found grievously injured. The primary suspect was the father of the deceased children, Baljinder Kumar Kala. The prosecution's case was built on the alleged motive of a monetary dispute. The appellant's sister, Rekha Rani, had divorced her husband, Haria, and the appellant's mother-in-law, PW2-Manjit Kaur, had stood as a guarantor for a Rs. 35,000 maintenance payment that was never made. The prosecution claimed this led to escalating fights, with the appellant allegedly threatening to kill his wife and children if the money was not paid.  

Flaws in Witness Testimonies and Investigation:

The Supreme Court identified significant contradictions and deficiencies in the prosecution's evidence, particularly in the testimonies of its three key witnesses: PW1-Vijay Kumar (the complainant), PW2-Manjit Kaur (the alleged eyewitness), and PW17-Harry (an injured child witness).

• Contradictory Statements from Key Witnesses: The Court found that the testimonies of PW1 and PW2 were "riddled with contradictions". For instance, PW1's account of his presence at the crime scene was deemed "highly improbable" because his residence and cycle shop were 10 kilometers away, contradicting PW2's claim that his shop was only two buildings away. The Court also noted inconsistencies in PW2's own account of events, pointing out that she gave different versions of how she arrived at the scene and whether she witnessed the crime or simply heard a noise. The Court classified these as "major" contradictions that "carve a gaping hole in the prosecution story altogether".
• Unreliable Recovery Evidence: The recovery of the murder weapon (a gandasi), blood-stained clothes, and a bicycle, allegedly based on the appellant's disclosure statement, was not supported by any independent witnesses. The Court noted a "long delay of two months" in the discovery, which made the evidence "highly questionable". Furthermore, the investigating officer admitted that the weapon was later misplaced and no forensic analysis was presented in court, which the Supreme Court called "utterly deplorable" and a reflection of a lack of regard for investigative protocols.
• Questionable Child Witness Testimony: While acknowledging the competency of the child witness, PW17-Harry, the Court concluded that he did not actually "witness" the incident. In his cross-examination, Harry stated that he was half asleep and became unconscious after receiving the first injury.

Rejection of the High Court's Rationale:

The Supreme Court also critiqued the High Court's reasoning, particularly its use of Section 106 of the Evidence Act to place the burden of proof on the appellant to explain his injuries. The High Court had presumed that the appellant's injuries were sustained during the assault. The Supreme Court, however, held that this was an "unwarranted application of the provision" because the prosecution had failed to establish the appellant's presence at the crime scene through direct, circumstantial, oral, or forensic evidence.

Conclusion:

The Supreme Court ultimately found that the prosecution had failed to meet the strict standard of proof required in a murder case. The major contradictions in witness statements and the "glaring investigative defects" meant that the appellant's guilt was not proven beyond a reasonable doubt. The Court concluded that "the standard of proof is an absolutely strict one and cannot be faltered with". As a result, the Court set aside the High Court's judgment, acquitted the appellant, and ordered his immediate release unless he was required in another case.