KARANDEEP SHARMA @ RAZIA @ RAJU VERSUS STATE OF UTTARAKHAND, 2025
The Supreme Court overturns death penalty due to flaws in trial procedures, including improper admission of confessional statements and DNA evidence.
Judgement Details
Court
Supreme Court of India
Date of Decision
7 April 2025
Judges
Justice Vikram Nath ⦁ Justice Sanjay Karol ⦁ Justice Sandeep Mehta
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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Accused: Karandeep Sharma (also known as Razia or Raju) was convicted for the rape and murder of a minor.
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Conviction: The trial court sentenced him to death, under sections 376A, 302, 366, 363, 201 of IPC, and sections 5/6 of POCSO Act.
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Confessions: During the trial, the investigating officer narrated the appellant's confessions, which had been made during the investigation and not before a magistrate.
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DNA Evidence: The prosecution relied on DNA evidence, but failed to examine the scientific expert who carried out the DNA profiling. This led to doubts about the authenticity of the DNA report.
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Trial Irregularities: The trial court admitted the confessions and DNA report without properly following legal procedures.
Issues
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Whether the trial court erred in admitting the confessional statements made by the appellant during the investigation, which were narrated by the investigating officer, in violation of Section 164 of the CrPC and the Indian Evidence Act?
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Whether the DNA profiling report submitted in evidence was admissible, given that the scientific expert who conducted the profiling was not examined and the chain of custody of the samples was not properly established?
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Whether the procedural flaws in the trial, including the improper admission of confessions and the failure to establish the chain of custody for forensic evidence, led to an unsafe conviction and justifies setting aside the death sentence imposed on the appellant?
Held
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The Supreme Court overturned the conviction of the appellant.
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Key points:
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The trial was flawed due to the improper admission of confessions.
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DNA evidence was inadmissible due to the failure to examine the scientific expert.
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The Court found that the prosecution failed to establish the integrity of the forensic samples, further weakening the case.
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The death penalty was set aside due to the lack of reliable evidence.
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Analysis
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Confession Admissibility:
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The Court emphasized that confessions made during an investigation must be recorded by a magistrate to be admissible in evidence, according to Section 164 of the CrPC.
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The Court criticized the trial court for allowing the police officer to narrate the confession, which was illegal under the Indian Evidence Act.
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DNA Evidence:
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The Court stressed that DNA evidence cannot be accepted as valid without ensuring the integrity and chain of custody of the forensic samples.
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The failure to examine the scientific expert who conducted the DNA profiling violated the Evidence Act and rendered the DNA report unreliable.
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Impact on Conviction: The Court found that the trial court's errors compromised the prosecution's case, leading to the conclusion that the conviction could not stand.