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State through SHO, Khan Sahib, Budgam vs Gulzar Ahmad Peer, 2025

The Supreme Court upheld the acquittal of Gulzar Ahmad Bhat (Gulzar Peer) in a 2013 rape case from Budgam, Jammu and Kashmir.

Supreme Court of India·21 May 2025
State through SHO, Khan Sahib, Budgam vs Gulzar Ahmad Peer, 2025
Ranbir Penal Code
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Judgement Details

Court

Supreme Court of India

Date of Decision

21 May 2025

Judges

Justice B.V. Nagarathna ⦁ Justice Satish Chandra Sharma

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

  • The case involves allegations of rape from 2013 in Budgam district, Jammu and Kashmir.

  • Gulzar Ahmad Bhat, also known as Gulzar Peer, a self-styled faith healer, was accused.

  • FIR was registered under Sections 376 and 109 of the Ranbir Penal Code.

  • The Sessions Court acquitted the accused in 2015, and the Jammu and Kashmir High Court upheld this acquittal in 2017.

  • The State filed an appeal in the Supreme Court challenging the acquittal.

Issues

  1. Whether the acquittal by the Sessions Court and High Court was justified based on evidence?

  2. Whether prosecution witnesses’ testimonies were credible to warrant conviction?

  3. Whether the Supreme Court should interfere with concurrent acquittal findings?

Held

  • The Court highlighted the principle that the benefit of doubt must always be given to the accused in criminal cases. In the present matter, the inconsistencies in witness testimonies and the lack of concrete evidence meant that the benefit of doubt was rightly extended by the lower courts.

  • Therefore, the Supreme Court dismissed the appeal filed by the State of Jammu and Kashmir, upholding the acquittal of Gulzar Ahmad Bhat (Gulzar Peer) and the other accused. The judgment serves as an important reminder of the judiciary’s duty to protect individuals from wrongful conviction and to respect the findings of fact made by courts closest to the evidence.

Analysis

  • The Court emphasized the high threshold for overturning acquittals, citing precedents: Yashwant & Ors. v. State of Maharashtra (2019) and Rajesh Prasad v. State of Bihar (2022).

  • Both lower courts had carefully evaluated the evidence and found it insufficient to convict.

  • The State failed to show any significant error or contradiction justifying interference.

  • The judgment protects accused persons from wrongful conviction unless clear evidence exists.