Kiran Raj

The Supreme Court of India Division Bench of Justice J.B. Pardiwala and Justice Sandeep Mehta has dismissed a criminal appeal against a conviction for murder under Section 302 read with Section 34 of the Indian Penal Code and the Arms Act. While upholding the life sentence imposed by the trial court and affirmed by the Punjab and Haryana High Court, the Court issued a strong caution to High Courts, reiterating that reasoned judgments must be uploaded without delay once the operative part is pronounced. The Bench stressed that judgments should be made available to parties within three months of reserving, observing that prolonged delays in criminal matters may undermine the right of litigants to pursue timely remedies.

The case arose from a First Information Report registered on 22 July 1998 at City Sirsa Police Station. The complainant Balbir Singh, an injured eyewitness, alleged that while visiting relatives in Sirsa he accompanied them to National College. At the canteen area, the victim Shiv Dutt Singh was confronted by several accused, including the appellant Rajan, who was armed with a pistol. The FIR recorded that Rajan fired at the victim but missed, following which co-accused Naresh and Vikas discharged firearms striking the victim in the chest and abdomen. Rajdeep Singh allegedly carried a sword but discarded it at the scene. The victim was transported to Civil Hospital, Sirsa, where he succumbed to firearm injuries within half an hour.

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The investigation led to the arrest of Vikas, Naresh, and Rajan. A charge sheet was filed for offences under Sections 302/34 IPC and Sections 25 and 27 of the Arms Act. The trial included testimony from fourteen witnesses, among them two eyewitnesses, Balbir Singh (PW-8) and Bishan Singh (PW-10), as well as medical professionals and police officials. Documentary evidence included the FIR, medical reports, and seizure records.

Rajan denied involvement during his examination under Section 313 of the Code of Criminal Procedure, claiming false implication. The trial court convicted Rajan and Vikas, sentencing them to life imprisonment, while Naresh absconded but was later apprehended and convicted separately. Three co-accused—Jasbir Singh, Kirpa Ram, and Rajdeep Singh—were acquitted. The Punjab and Haryana High Court dismissed Rajan’s appeal in February 2016. His co-convict Vikas had earlier approached the Supreme Court, but his petition was dismissed in 2018. Rajan then filed the present appeal.

The Supreme Court examined the submissions of both sides. The appellant’s counsel argued that the High Court’s judgment was uploaded two years and five months after pronouncement, causing prejudice. It was further submitted that absence of recovery of the pistol attributed to the appellant cast doubt on the prosecution case.

The Court recorded: “There is no good reason for us to disbelieve PW 8 – Balbir Singh and PW 10 – Bishan Singh respectively.” It explained that appreciation of eyewitness testimony does not require mathematical precision: “Minor discrepancies on trivial matters not touching the core of the case… would not ordinarily permit rejection of the evidence as a whole.”

On the issue of weapon recovery, the Bench noted: “Just because the firearm alleged to have been used and fired by the appellant–herein was not recovered… would not render the ocular version of the two eyewitnesses doubtful.”

Addressing the delay in uploading the High Court judgment, the Court stated: “The delay at the instance of the High Court in uploading the Judgment after a period of about 2 years 5 months is a matter of grave concern. We should not overlook this fact. We have taken serious cognizance of this delay at the instance of the High Court.”

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The Bench stated earlier guidelines from Anil Rai v. State of Bihar requiring judgments to be pronounced and made available within prescribed timeframes. It observed: “We hope that we may not have to come across any matter wherein there is a delay at the end of the High Court in uploading the reasoned order more particularly after the operative part of the judgment is pronounced.”

The Supreme Court dismissed the appeal, affirming the conviction and life sentence imposed by the trial court and confirmed by the Punjab and Haryana High Court. The Bench declared: “In view of the aforesaid, this appeal fails and is hereby dismissed.”

 “Registry is directed to forward one copy each of this judgment to all the High Courts.”

Advocates Representing the Parties

For the Appellant: Ms. Tarannum Cheema, Advocate
For the Respondent (State of Haryana): Mr. Deepak Thukral, Advocate

Case Title: Rajan v. State of Haryana
Neutral Citation: 2025 INSC 1081
Case Number: Criminal Appeal No. 3904 of 2025 (@SLP (Crl.) No. 13881 of 2025)
Bench: Justice J.B. Pardiwala and Justice Sandeep Mehta