Application Of Evidence Law In High-Profile Criminal Cases
⚖️ 1. K.M. Nanavati v. State of Maharashtra (1962)
Citation: AIR 1962 SC 605
🔍 Case Summary:
Commander Nanavati was tried for shooting his wife’s lover. The case received national attention due to its sensational facts and media coverage.
🔑 Evidence Law Applied:
Section 8 (Motive, preparation, and conduct)
Section 27 (Discovery of facts through police interrogation)
Section 105 (Burden of proof in exceptions)
🧠 Legal Issues:
Whether Nanavati’s act was murder or culpable homicide not amounting to murder (provocation).
Whether the accused successfully proved the defence of grave and sudden provocation.
🧑⚖️ Court’s Findings:
The Supreme Court held that Nanavati did not act under sudden provocation, as there was a time gap between the provocation and the act.
The burden of proof for exceptions under IPC lies on the accused (Section 105).
Conduct and preparation indicated that the act was deliberate.
📌 Importance:
Illustrated how motive, preparation, and burden of proof play a role in determining the intent and nature of the offence.
⚖️ 2. State of Maharashtra v. Salman Khan (2002 Hit-and-Run Case)
Citation: Sessions Court & Bombay High Court Rulings (Trial & Appeal)
🔍 Case Summary:
Salman Khan was accused of running over five people while allegedly driving under the influence of alcohol.
🔑 Evidence Law Applied:
Section 65B (Admissibility of electronic records)
Section 45 (Expert opinion – forensic and medical)
Section 114 (Presumptions regarding facts)
🧠 Legal Issues:
Admissibility of CCTV footage and blood test reports.
Reliability of the testimony of the sole eyewitness (police constable).
Presumption of guilt from circumstantial and forensic evidence.
🧑⚖️ Court’s Findings:
The trial court convicted him, but the High Court acquitted, citing lack of reliable and admissible evidence.
Procedural lapses and improper electronic evidence certification weakened the prosecution’s case.
Key witness credibility was questioned.
📌 Importance:
Emphasized strict compliance with Section 65B for admissibility of digital evidence and how procedural flaws can lead to acquittals.
⚖️ 3. Nirbhaya Case – Mukesh & Others v. State (NCT of Delhi) (2017)
Citation: (2017) 6 SCC 1
🔍 Case Summary:
Gang rape and brutal murder of a young woman in Delhi in 2012 shocked the nation.
🔑 Evidence Law Applied:
Section 9 (Identification evidence)
Section 27 (Discovery of weapon)
Section 32 (Dying declaration)
Section 114A (Presumption of absence of consent in rape cases)
🧠 Legal Issues:
Validity of multiple dying declarations.
Use of DNA evidence and recovery of the weapon.
Admissibility and credibility of forensic and medical evidence.
🧑⚖️ Court’s Findings:
All dying declarations were found to be voluntary, truthful, and consistent.
DNA evidence matched the accused.
The presumption under Section 114A was invoked as the victim had no opportunity to consent.
📌 Importance:
Landmark case showing the weight of dying declarations, forensic evidence, and statutory presumptions in sexual offences.
⚖️ 4. Aarushi Talwar Case (2013 Trial Court & 2017 Allahabad HC)
Citation: Rajesh Talwar & Nupur Talwar v. State of U.P.
🔍 Case Summary:
Teenager Aarushi Talwar and domestic help Hemraj were found murdered. Her parents were accused.
🔑 Evidence Law Applied:
Circumstantial evidence (Sections 3, 101–104)
Section 106 (Facts especially within knowledge of accused)
Section 27 (Recovery of murder weapon)
🧠 Legal Issues:
No direct evidence; the case rested on circumstantial chain.
Whether the parents had exclusive access to the crime scene (locked apartment).
Use of forensic inconsistencies and missing links.
🧑⚖️ Court’s Findings:
Trial court convicted them based on inference under Section 106, but the High Court acquitted due to reasonable doubt.
Court held that prosecution failed to establish a complete and coherent chain of circumstances.
📌 Importance:
Illustrated the limitations of Section 106 and the need for a complete and unbroken chain in circumstantial evidence cases.
⚖️ 5. Jessica Lal Murder Case – Manu Sharma v. State (2010)
Citation: (2010) 6 SCC 1
🔍 Case Summary:
Model Jessica Lal was shot dead at a party in Delhi. The accused, Manu Sharma, was initially acquitted but later convicted by the High Court.
🔑 Evidence Law Applied:
Section 6 (Res gestae – spontaneous statements)
Section 157 (Statements corroborating oral evidence)
Section 3 (Relevancy and appreciation of evidence)
🧠 Legal Issues:
Reliance on witness testimonies that later turned hostile.
Role of media and public pressure in reopening the case.
Whether circumstantial and corroborative evidence could sustain conviction.
🧑⚖️ Court’s Findings:
The SC upheld conviction, noting that key witnesses turning hostile did not render entire prosecution weak.
Independent corroboration, ballistic reports, and public behavior of the accused contributed to establishing guilt.
📌 Importance:
Highlighted the use of res gestae and corroborative evidence, and how courts may rely on partial testimonies when consistent with other evidence.
⚖️ 6. Best Bakery Case – Zahira Sheikh v. State of Gujarat (2004)
Citation: (2004) 4 SCC 158
🔍 Case Summary:
Case involved burning of Best Bakery during Gujarat riots. Witnesses turned hostile in the original trial.
🔑 Evidence Law Applied:
Section 154 (Hostile witnesses)
Section 165 (Judge’s power to ask questions)
Section 114 (Presumption from human conduct)
🧠 Legal Issues:
Whether witnesses turning hostile undermines the entire trial.
Whether retrial could be ordered on the basis of miscarriage of justice.
🧑⚖️ Court’s Findings:
Supreme Court ordered retrial in Maharashtra due to state failure to protect witnesses.
Upheld that the court can discard false parts and rely on truthful elements of hostile witness testimony.
Emphasized judicial duty to reach truth despite procedural setbacks.
📌 Importance:
Pivotal case on witness protection, hostile witnesses, and judicial powers in extracting truth.
🔍 Summary of Key Evidence Law Principles Applied:
| Section | Principle | Applied In |
|---|---|---|
| Section 3 | Relevance of evidence | Jessica Lal, Aarushi |
| Section 6 | Res gestae | Jessica Lal |
| Section 8 | Motive & conduct | Nanavati |
| Section 27 | Discovery based on confession | Nirbhaya, Nanavati |
| Section 32 | Dying declaration | Nirbhaya |
| Section 45 | Expert/Forensic opinion | Salman Khan, Nirbhaya |
| Section 65B | Digital evidence | Salman Khan |
| Section 106 | Facts within special knowledge | Aarushi Talwar |
| Section 114A | Presumption in rape | Nirbhaya |
| Section 154 | Hostile witness | Best Bakery |
🧠 Conclusion:
High-profile cases often test the robustness and flexibility of Evidence Law in India. These rulings demonstrate:
The growing role of forensics and digital evidence
Importance of procedural compliance (especially with Sections 65B & 27)
Critical thinking around hostile witnesses and circumstantial chains
Need for judicial sensitivity and active role in delivering justice
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