Supreme Court bench acquits Govind in the 2016 Haryana murder case due to unreliable evidence and procedural lapses.
CASE SUMMARY
This Supreme Court judgment in Govind vs. State of Haryana sets aside the appellant's conviction for murder under Section 302 IPC and Section 25 of the Arms Act.
The prosecution relied mainly on recovery of a pistol and an FSL report, but both eyewitnesses turned hostile and failed to identify the accused. The recovery was made from an unlocked box accessible to family members, with no independent witnesses and an incomplete chain of custody. The alleged motive was unproved and primarily attributable to acquitted co-accused. Holding that guilt was not proven beyond reasonable doubt, the Court acquitted Govind.
| Section | Details |
| Case Title | Govind vs. State of Haryana, Criminal Appeal No. 5641 of 2024 |
| Introduction | Appeal against conviction under Section 302 IPC and Section 25 Arms Act, where the Trial Court and High Court upheld guilt mainly on the basis of recovery and FSL report. |
| Factual Background | Promila was shot dead on 12.06.2016. FIR was filed by her brother Pradeep. Initial FIR named unknown assailants; later supplementary statement implicated the appellant Govind and two others. Recovery of pistol and cartridges was made based on disclosure. |
| Legal Issues | Whether conviction can be sustained solely on recovery and FSL report when eyewitnesses turned hostile, motive unproved, and recovery made from a place accessible to others with no independent witnesses. |
| Applicable Law | Sections 25-27 Evidence Act; Section 25 Arms Act; Precedents such as Manjunath, Raja Khan, Jaikam Khan, Nikhil Chandra Mondal. |
| Analysis | Court held that recovery was from an open, accessible place; chain of custody was broken; no proof that pistol recovered was used in murder. Eyewitnesses turned hostile; motive against appellant unproved; prosecution failed to prove guilt beyond reasonable doubt. |
| Conclusion | Conviction set aside; appellant acquitted and ordered to be released. |
| Current Scenario | As of November 2025, Govind stands acquitted; no further appeal reported in the judgment. |
"Mere recovery and an FSL report cannot substitute proof of guilt when eyewitnesses turn hostile and the chain of custody remains unestablished."
SOURCE - SUPREME COURT OF INDIA
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