SC Annoyed at Careless Investigation, Acquits Man After 6 Years as Undertrial, and Orders Rs. 6 Lakh Compensation from the State

In a strong judgment delivered on October 26, 2026, the Supreme Court of India strongly condemned careless police investigations that jeopardize personal liberty. Justice K. Vinod Chandran, speaking for the bench, highlighted a case where an innocent man was incarcerated for six years as an undertrial in a murder case without a shred of credible evidence, ultimately leading to his acquittal.

Background

• The Missing Person & FIR: On October 18, 2019, the informant’s (PW1) son went missing while returning from his workplace on his motorcycle. A missing person report was filed, followed by a subsequent report on October 19 alleging abduction by unknown persons.
• The Arrest: The petitioner (Arun @ Deepak) was never named in the FIR or in initial Section 161 statements. He was subsequently implicated solely based on unclear CCTV footage and the confession of a co-accused.
• The Alleged Recovery: Police claimed to have recovered charred bones, a motorcycle, and belongings of the deceased near a drain and from the house of a co-accused. However, the bones were never conclusively identified through DNA profiling to match the deceased, and the motorcycle was never produced or proved during the trial.
• Trial and Acquittal: Following an earlier interim direction by the Supreme Court on March 23, 2026, ordering the trial to be completed within three months, the Trial Court acquitted the petitioner of all charges under Sections 364, 302, and 201 of the IPC.

Court’s Observations and Strict Strictures

1. Appalling Investigative Lapses

The Supreme Court expressed shock at the absolute lack of rudimentary investigative rigor, pointing out multiple fatal flaws in the prosecution’s case:

• No DNA Confirmation: Although the doctor (PW2) testified that DNA testing was necessary to establish the identity of the recovered bones, no DNA profiling or matching with the father (PW1) was ever conducted.
• Missing Electronic Evidence: Critical electronic evidence, including CCTV footage and Call Detail Records (CDRs), were introduced without the mandatory supporting certificate under Section 65B of the Indian Evidence Act.
• Defective Seizures: Recoveries were made without recording any statement regarding concealment from the accused under Section 27 of the Evidence Act. Furthermore, no evidence substantiated the purchase of petrol used to burn the body.

2. Role of Investigation and Prosecution Agencies

• The Court emphasized that investigation and prosecuting agencies are not mere instruments to secure convictions by any means; they are essential stakeholders in the justice delivery system tasked with ensuring justice for the accused as well.
• Deprecating the casual manner in which investigations are carried out, the Court noted that six years were erased from an innocent man’s life on the strength of a concocted story built entirely on surmises and conjectures.

Final Directions and Compensation

• State Compensation: Recognizing that the petitioner was a victim of a systemic failure, the Supreme Court directed the State of U.P. to pay Rs. 6,00,000/- as compensation to the petitioner within one month. Failure to pay within the stipulated time will attract an interest rate of 18% per annum.
• Administrative Action: A copy of the judgment was ordered to be dispatched to the Director General of Police and the Home Secretary of the State of Uttar Pradesh to educate and reform police officers on proper investigative procedures.

Citation: Arun @ Deepak v. State of U.P. (2026 INSC 1150)