Conviction Overturned Due to Insufficient Evidence and Procedural Lapses in Chain of Custody of DNA Samples
In a significant ruling, the Allahabad High Court has overturned the conviction of Neerajpal, who was previously sentenced to life imprisonment for the alleged rape and murder of a 14-year-old girl in Hardoi district in 2011. The Division Bench comprising Justices Rajesh Singh Chauhan and Rajeev Bharti delivered the judgment on July 23, 2026, citing inadequate evidence and serious procedural lapses by the prosecution.
The case, which rested solely on circumstantial evidence, was scrutinized for its reliance on the "last seen" theory, recoveries made during the investigation, and the evidentiary value of the DNA report. The court found that the "last seen" testimony provided by Pradeep Kumar (P.W.2) was inconsistent and lacked independent corroboration, as the other purported witness, Manoj Kumar (P.W.3), turned hostile.
Furthermore, the court noted serious deficiencies in the recoveries made during the investigation. Key witnesses to the recoveries either turned hostile or were not presented by the prosecution, casting doubt on their authenticity. The absence of credible evidence linking the recovered mobile phone and driving license directly to Neerajpal further weakened the prosecution's case.
The judgment also highlighted procedural failures in the handling of DNA evidence. The court criticized the lack of strict adherence to the chain of custody requirements for biological samples, which compromised their integrity. The DNA expert was not called to testify, and the samples remained in police custody for five days without clear documentation of their handling, raising questions about potential tampering.
The court underscored the need for meticulous handling of scientific evidence, emphasizing that suspicion cannot replace legal proof. The judgment directed state authorities to ensure compliance with proper procedures for handling DNA evidence and other scientific material in criminal investigations.
Having spent approximately 14 years in incarceration, Neerajpal was ordered to be released unless required in any other case. The court also mandated the refund of any fines paid by the appellant.
This ruling not only highlights the necessity for stringent procedural safeguards in the collection and presentation of forensic evidence but also serves as a crucial reminder of the high standard of proof required in criminal cases.
Bottom Line:
Circumstantial Evidence - Conviction based on circumstantial evidence requires a complete and unbroken chain of circumstances pointing exclusively towards the guilt of the accused and excluding any hypothesis consistent with innocence.
Statutory provision(s): Indian Penal Code Sections 302, 376, 201; Criminal Procedure Code Sections 313, 374(2), 161, 437A; Evidence Act Section 45
Neerajpal v. State of U.P., (Allahabad)(Lucknow)(DB) : Law Finder Doc id # 2948575
