Randeep Singh vs State of Haryana (2024) - Case Analysis

Introduction of Randeep Singh Rana vs State of Haryana (2024)

The case of Randeep Singh Rana vs State of Haryana (2024) centres around the conviction of the accused based on circumstantial evidence and electronic records. The accused in this case were charged with the abduction and murder of Gurpal Singh whose body was later discovered in a canal. The Supreme Court in this case introspected issues regarding the admissibility of evidence such as CCTV footage and confessions and found lapses in the case of the Prosecution. The Supreme Court on 22nd November, 2024 overturned the convictions and held that the prosecution failed to establish the guilt of the accused beyond doubt.

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Why in the Spotlight? - Randeep Singh Rana vs State of Haryana (2024)

The 3-Judge Bench of the Supreme Court comprising Justice Abhay S. Oka, Justice Ahsanuddin Amanullah and Justice AG Masih overturned the convictions and held that the prosecution failed to establish the guilt of the accused beyond doubt.

Historical Context and Facts of Randeep Singh Rana vs State of Haryana (2024)

The case at hand revolves around the issues regarding the circumstantial evidence, procedural compliances and admissibility of electronic evidence. The following are the brief facts of the case -

Background and Accusations

The Appellants along with the other accused were charged under Section 364, Section 302, Section 201, Section 212 and Section 120-B of the Indian Penal Code, 1860. There were eight accused including Respondent Nos. 2 to 6 and Bhim Sain alias Kaka Ganth.

Incident and Abduction

Gurpal Singh (the deceased) father of the complainant Jagpreet Singh (PW-8) left his home in a Ford Fiesta car on 8th July, 2013. He visited his sister Paramjeet Kaur (PW-26) at around 6:30 PM. After meeting her, while returning home and reaching the main gate of Prabhu Prem Puram Ashram unknown individuals in a white car intercepted him. The deceased was abducted and his car was also taken by the assailants.

Filing of the FIR

Jagprret Singh (PW-8) initiated a search when his father Gurpal Singh did not return home but failed to locate him. Following this, a First Information Report was filed.

Recovery of the Body

The torso and other body parts of Gurpal Singh were found in a canal on 9th July, 2013 confirming his abduction and subsequent murder.

Evidence and Witnesses by the Prosecution

The Prosecution presented evidence through twenty-nine witnesses. Jagpreet Singh (PW-8) filed the FIR, Paramjeet Kaur (PW-26) who was the last person to meet the deceased Gurpal Singh. Other witnesses corroborated the sequence of events and linked the Appellants to the crime.

Decision of the Session Court

The Sessions Court convicted all accused for the offences under Section 364, Section 302 and Section 120B and sentenced them to life imprisonment. They were also convicted under Section 201 and sentenced to rigorous imprisonment for three years.

Appeal in the High Court of Punjab and Haryana

Aggrieved by the decision of the Session Court the High Court acquitted the other accused while upholding the conviction of the Appellants.

Appeal in the Supreme Court

The Appellants filed an appeal in the Supreme Court challenging the decision of the Punjab and Haryana High Court.

Issue addressed in Randeep Singh Rana vs State of Haryana (2024)

The main question which was addressed in this case was whether the conviction of the Appellants based primarily on circumstantial evidence and electronic records could be upheld?

Legal Provisions involved in Randeep Singh Rana vs State of Haryana (2024)

In this case Section 25, Section 26 and Section 27 of the Indian Evidence Act played a significant role. The following are the legal analysis of these provisions -

Section 25 of the Indian Evidence Act, 1872

Section 25 of the IEA provides that no confession made to a police-officer shall be proved as against a person accused of any offence.

Section 26 of the Indian Evidence Act, 1872

Section 26 of IEA deals with the admissibility of confessions made while a person is in police custody. It states that a confession made by a person while in police custody cannot be used against that person unless it is made in the immediate presence of a Magistrate.

Section 27 of the Indian Evidence Act, 1872

Section 27 of IEA allows information given by an accused in police custody to be admissible in court but only to the extent that it leads to the discovery of a fact. The information even if it amounts to a confession can only be used if it directly relates to the discovery of a fact and not the entire confession or statement itself.

Judgment and Impact of Randeep Singh Rana vs State of Haryana (2024)

The Supreme Court held that the Prosecution has failed to provide any material evidence due to critical lapses in evidence and procedural compliance. The Court observed that the CCTV footage showing the accused and the vehicle involved was inadmissible as it lacked a certificate under Section 65B of the Evidence Act. The Court also noted that the CD containing the footage bore no markings or signatures to verify its authenticity. 

The Court noted that circumstantial evidence presented by the Prosecution failed to meet the stringent standards set in Sharad Birdhichand Sarda v. State of Maharashtra. The Court ruled that the chain of circumstances was incomplete and some critical links were either unproven or contradicted. The recovery of body parts was based on independent information received by the police and could not be linked to the disclosure of the accused.

The Supreme Court also ruled that the confessions allegedly made by the accused to the police were not admissible under Section 25 and Section 26 of the Evidence Act. The Court noted that the Trial Court’s reliance on these confessions ignored established legal principles including the limited admissibility of disclosures under Section 27. The Court highlighted the distinction between admissible information leading to the discovery of facts and inadmissible details about past use or history of the recovered objects.

In conclusion, the Supreme Court concluded that the Prosecution failed to establish the guilt of the accused. The Court ruled that the accused were entitled to the benefit of the doubt. Thus, the Supreme Court set aside the convictions of the accused.

Conclusion

In Randeep Singh Rana vs State of Haryana (2024) the Supreme Court ruled that the Prosecution failed to prove the guilt of the accused due to issues with evidence and procedures. As a result, the Supreme Court overturned the convictions and gave the accused the benefit of the doubt.