Beyond a Reasonable Doubt: Why a Lack of Evidence Led to Acquittal in the Shanti Devi Murder Case.
06-August-2025
Acquittal >> Criminal Law
The recent acquittal of Shanti Devi and Rajbir by a higher court serves as a compelling case study on the critical role of circumstantial evidence and the principle of reasonable doubt in India's criminal justice system. The case, which overturned convictions by both the trial court and the High Court of Punjab and Haryana, highlights the stringent standards of proof required to establish guilt, especially when direct evidence is absent. This article analyzes the court's reasoning, focusing on the five golden principles of circumstantial evidence and how the prosecution's case failed to meet these fundamental legal requirements.
The Prosecution's Case: A Flimsy Web of Circumstances
The case began with the recovery of a human body, later identified as Balwant, from a water tank in Hisar on December 23, 1997. The prosecution’s case against the three accused—Shanti Devi, her son Rajbir, and a woman named Veena—was built entirely on a chain of circumstantial evidence. The primary elements of their theory were:
Motive: The prosecution alleged two motives: first, that Shanti Devi and Rajbir were in illegal occupation of Balwant's house and refused to vacate; and second, that Balwant was involved in an illicit relationship with Veena.
Last Seen Theory: A witness, Krishan Kuli (PW-15), claimed he saw the three accused quarreling with Balwant on the evening of December 20, 1997.
Extra-Judicial Confessions: The prosecution relied on multiple accounts of the accused confessing to the crime to various individuals, including Krishan Kuli.
Incriminating Recoveries: The police claimed to have recovered blood-stained articles and the murder weapons—an axe (Kulhari) and a Bugda—based on the disclosure statements of the accused.
The Court's Deconstruction of the Evidence:
The higher court meticulously examined each link in the prosecution's chain of evidence, applying the well-established "five golden principles" from the landmark case of Sharad Birdhichand Sarda v. State of Maharashtra. These principles require that the circumstances leading to a conclusion of guilt must be fully established, consistent only with the hypothesis of guilt, conclusive in nature, exclude every other possible hypothesis, and form a complete chain of evidence that leaves no room for reasonable doubt. The court found that the prosecution's case failed on every count.
Failure to Prove Motive:
The court noted significant contradictions in the testimony of the informant, Har Nath (PW-11), Balwant's father. While the FIR alleged illegal occupation, the witness himself stated that Shanti Devi was a tenant. These two accounts are "diametrically opposite and cannot be reconciled." Furthermore, the alleged illicit affair was not mentioned in the informant's examination-in-chief, and he admitted he did not know Veena previously, casting serious doubt on the veracity of the claim. The court also observed that Balwant's wife, Savitri, who would have been the most knowledgeable person about these issues, was never called as a witness. The court concluded that the theory of enmity was not established, especially given that Balwant frequently stayed in the very house where the accused lived.
The Unreliable Last Seen Theory and Extra-Judicial Confessions:
The court found the testimony of Krishan Kuli (PW-15) to be completely unreliable. He was a "chance witness" who had no plausible reason to be in the locality on the day of the alleged quarrel. Even more dubiously, the witness claimed that 15 to 16 days after the incident, Rajbir, a person he barely knew, approached him and confessed to the murder. The court found this to be "absolutely unworthy of credence" and noted that the confessions of all three accused were presented through witnesses who had no prior connection with them, leading to the conclusion that the extra-judicial confessions were a "cock and bull story created by the police."
The court also dismissed the confessional statement of Veena, made in the presence of police, as it was inadmissible under Sections 25 and 26 of the Indian Evidence Act.
The Flawed Recovery of Weapons:
The alleged recoveries of the weapons—the Bugda and the Kulhari—also came under a "grave cloud of doubt." The court pointed out that the witness to the recovery, Bhagatu (PW-14), did not mention the presence of any of the accused when the items were recovered from the sewerage. This contradicted the police's claim that the recoveries were made based on the accused's disclosure statements. Most critically, the Forensic Science Laboratory (FSL) report was negative, as it could not detect any human blood on the weapons. This rendered the alleged recoveries "inconsequential," as they provided no tangible link to the murder.
Conclusion and the Extension of Justice:
The court's analysis demonstrated that the prosecution's evidence was a collection of weak, contradictory, and uncorroborated claims. The chain of circumstances was not complete, and each link was found to be either unreliable or fabricated. The judgments of the trial court and the High Court were found to be based on a gross misappreciation of the evidence.
Consequently, the court quashed the convictions of Shanti Devi and, in a significant application of legal precedent, extended the benefit of its judgment to the non-appealing accused, Rajbir. Citing the principle of "denial of access to justice" for those unable to file an appeal due to compelling reasons like lack of finances, the court acquitted both individuals. This case serves as a powerful reminder that in a criminal trial based on circumstantial evidence, the prosecution must prove guilt beyond all reasonable doubt, leaving no room for a plausible alternative hypothesis of innocence.
Section 34., Indian Penal Code - 1860
Section 201., Indian Penal Code - 1860
Section 302., Indian Penal Code - 1860
Section 173., Code of Criminal Procedure - 1973
Code of Criminal Procedure, 1973