DASHWANTH v. THE STATE OF TAMIL NADU

Supreme Court of India
2025 INSC 1203

Discusses fair trial principles, evaluating circumstantial evidence, and handling forensic evidence, applicable across legal domains.

Legal Discussion:

  1. The Indian Penal Code, 1860: The judgment discusses Sections 302, 201, 363, 366, and 354-B of the IPC. It notes that the trial court found the appellant guilty under these sections. The judgment analyzes the evidence presented by the prosecution to determine if the guilt was established beyond reasonable doubt, ultimately concluding that the prosecution failed to prove its case. The judgment highlights the importance of establishing a complete and unbroken chain of circumstances in cases based on circumstantial evidence.
  2. The Protection of Children from Sexual Offences Act, 2012: The judgment refers to Section 8 read with Section 7 and Section 6 read with Section 5(m) of the POCSO Act. The trial court convicted the appellant under these provisions. The Supreme Court, however, focuses on the flawed investigation and the lack of credible evidence, leading to the acquittal of the appellant.
  3. The Code of Criminal Procedure, 1973: The judgment discusses Sections 313, 315, 366, 374(2), and 207 of the CrPC. Section 313 CrPC was used to question the appellant. Section 315 CrPC relates to the written statement filed by the appellant. Section 366 CrPC concerns the reference made by the trial court to the High Court for confirmation of the death sentence. Section 374(2) CrPC pertains to the appeal preferred by the appellant to the High Court. Section 207 CrPC mandates providing copies of relied-upon documents to the accused, and the judgment notes the non-compliance with this section. The judgment emphasizes the importance of fair trial and the right of the accused to defend himself.
  4. The Indian Evidence Act, 1872: The judgment refers to Section 114 regarding the presumption that can be drawn from the recovery of stolen property. It also discusses Sections 25 and 165 of the Act. The judgment notes that the trial court allowed the entire confessional statement of the appellant to be reproduced, which is in contravention of Section 25 of the Indian Evidence Act. Section 165 discusses the court's power to put questions to witnesses.
  5. Constitution of India: The judgment refers to Articles 21 and 22(1) of the Constitution of India. It states that the appellant's right to a fair trial was violated, disregarding the mandate of these articles. The judgment emphasizes the constitutional right of an accused to defend himself and the importance of legal representation.
  6. General Principles of Law: The judgment extensively discusses the principles of fair trial, the importance of legal representation, and the burden of proof in cases based on circumstantial evidence. It emphasizes that the prosecution must prove the guilt of the accused beyond reasonable doubt and that the courts must adjudicate cases based on individual merits and strict conformity with the law. The judgment also highlights the importance of maintaining the chain of custody of forensic evidence.

List of Laws: The Indian Penal Code, 1860; The Protection of Children from Sexual Offences Act, 2012; The Code of Criminal Procedure, 1973; The Indian Evidence Act, 1872; Constitution of India; General Principles of Law

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