Teja Singh & Anr. v. State of Punjab, 2026
The Court reaffirmed that motive assumes importance in cases resting substantially on circumstantial evidence.
Judgement Details
Court
Punjab and Haryana High Court
Date of Decision
28 January 2026
Judges
Justice N. S. Shekhawat & Justice Sukhvinder Kaur
Citation
Acts / Provisions
Facts of the Case
-
Teja Singh was convicted in 2004 by the Additional Sessions Judge for murdering his pregnant wife Virpal Kaur by setting her on fire.
-
His brother Baljit Singh @ Goga was also convicted with the aid of common intention under Section 34 IPC.
-
The prosecution alleged that:
-
Virpal Kaur wanted a separate residence.
-
Teja Singh wanted to live jointly with his brother.
-
Due to this dispute, the accused poured kerosene on her and set her ablaze.
-
-
The prosecution case was primarily based on a dying declaration allegedly made on 11 July 2002.
-
Baljit Singh died in 2015, leading to abatement of proceedings against him.
-
Teja Singh challenged the conviction before the High Court.
Issues
-
Whether the alleged motive of a dispute over separate residence was sufficient and credible to establish the offence of murder?
-
Whether the dying declaration relied upon by the prosecution was reliable and safe to base a conviction?
-
Whether the prosecution proved the guilt of the appellant beyond reasonable doubt?
-
Whether the defence version that the deceased committed suicide was more probable in the facts and circumstances of the case?
-
Whether the conduct of the accused was consistent with guilt or indicative of innocence?
Judgement
-
The High Court allowed the appeal filed by Teja Singh.
-
It set aside the judgment of conviction and life sentence passed by the trial court.
-
The Court held that:
-
The alleged motive was extremely weak and unbelievable.
-
The dying declaration suffered from serious procedural and medical infirmities.
-
The prosecution failed to establish guilt beyond reasonable doubt.
-
-
Teja Singh was acquitted of all charges.
Held
-
A trivial dispute over separate residence could not be accepted as a credible motive for murdering a pregnant wife.
-
The dying declaration was unsafe and unreliable to sustain conviction.
-
The defence version of suicide appeared more probable.
-
The prosecution failed to discharge its burden of proof.
Analysis
-
The Court reaffirmed that motive assumes importance in cases resting substantially on circumstantial evidence.
-
It held that where motive is weak or improbable, courts must exercise heightened caution.
-
The judgment critically scrutinised the dying declaration, noting:
-
It was recorded by a police officer, not a Magistrate, without explanation.
-
The medical endorsement was written by the investigating officer, not the doctor.
-
Medical evidence showed 99% burns with respiratory failure, casting doubt on the victim’s capacity to give a detailed statement.
-
-
The Court condemned the casual and mechanical approach of medical certification in dying declarations.
-
Allegations of beating after burning were rejected due to lack of medical corroboration.
-
Evidence of a bolted room from inside, broken door latch, and witness testimonies supported the possibility of suicide.
-
The Court found the conduct of the accused—taking the victim to hospitals and bearing treatment expenses—inconsistent with homicidal guilt.
-
The decision reinforces the principle that suspicion, however strong, cannot substitute proof.