State of Punjab vs. Gurpreet Singh [February 06, 2024]

The case arose from the murder of Amarjit Kaur, the former mother-in-law of Gurpreet Singh. The prosecution alleged that Gurpreet Singh, motivated by revenge after his failed marriage, committed the murder. The trial court convicted Gurpreet Singh under Section 302 IPC (murder) and related provisions, relying on eyewitness testimony and forensic evidence. However, the Punjab and Haryana High Court acquitted him, citing doubts about the prosecution’s case. The State of Punjab appealed to the Supreme Court.

Key Legal Issues

Whether the High Court erred in acquitting Gurpreet Singh despite credible evidence presented by the prosecution.

The sufficiency and reliability of eyewitness testimony and forensic evidence.

The standard for appellate interference with an acquittal in a murder case.

Supreme Court’s Analysis

The Supreme Court scrutinized the High Court’s reasoning and found that it had failed to properly appreciate the direct and corroborated evidence against Gurpreet Singh.

The Court emphasized that the trial court had rightly relied on natural eyewitnesses, whose presence at the scene was established, and their accounts were consistent and credible.

Forensic evidence, including the recovery of the murder weapon at Gurpreet Singh’s instance, further strengthened the prosecution’s case.

The motive—revenge for a failed marriage—was well established and supported by witness testimony and circumstances.

The Court reiterated that an appellate court should not overturn a conviction unless the trial court’s findings are perverse or unsupported by evidence. Here, the trial court’s conviction was based on sound appreciation of evidence, and the High Court’s acquittal was not justified.

Regarding the co-accused, the Supreme Court upheld their acquittal, noting insufficient evidence and plausible doubts about their involvement.

Judgment

The Supreme Court reversed the High Court’s acquittal of Gurpreet Singh, reinstating his conviction under Section 302 IPC and related provisions.

The acquittal of the co-accused by the High Court was affirmed due to lack of substantive evidence against them.

The Court reaffirmed the importance of prompt FIRs, credible eyewitnesses, and corroborative forensic evidence in upholding convictions in serious criminal cases.

Significance

This judgment reinforces the standards for evaluating evidence in murder cases, particularly the weight accorded to natural eyewitness testimony and forensic corroboration. It clarifies the appellate court’s limited scope in interfering with well-founded convictions and underscores the need for careful scrutiny before overturning trial court findings in serious criminal matters.

Citation:
State of Punjab v. Gurpreet Singh & Ors., [2024] 2 S.C.R. 1039, Supreme Court of India, decided on February 6, 2024.

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