New Delhi, August 28, 2025: The Supreme Court of India has acquitted two men, including a death row convict, in a 2012 rape and murder case of a 12-year-old girl in Lucknow, citing serious lapses in police investigation and prosecution. The judgment in Putai vs. State of Uttar Pradesh is a significant reminder of the importance of credible evidence and fair trial standards in criminal jurisprudence.
A three-judge Bench comprising Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta delivered the verdict on August 26, 2025, setting aside the convictions and sentences imposed by the trial court and later upheld by the Allahabad High Court.
The Court strongly criticized the “lackluster and shabby investigation” carried out by the police, which failed to prove the guilt of the accused beyond reasonable doubt, despite the seriousness of the crime.
Case Background
The tragic incident dates back to September 2012 when a 12-year-old girl from Lucknow went missing after stepping out of her home to relieve herself. Her family and villagers searched for her throughout the night but failed to locate her.
The following morning, villagers discovered her belongings, including footwear, a water container, and blood-stained underclothes, scattered in a field. Soon after, her naked body was found in an adjoining agricultural plot.
An FIR was lodged the same day under Sections 302 (murder), 201 (causing disappearance of evidence), and 376 (rape) of the Indian Penal Code (IPC). The post-mortem confirmed that the girl had been sexually assaulted and died due to strangulation.
Trial Court and High Court Convictions
During the investigation, the police claimed that a dog squad and recovered comb pointed towards two men from the locality — Putai and Dileep. Both were arrested in September 2012, and their blood samples were collected two months later.
The first DNA report (January 2014) was inconclusive. A supplementary DNA report (December 2014) suggested a match with the accused, but crucially, it was not proven in court through expert testimony and was never put to the accused for their explanation under Section 313 of the Code of Criminal Procedure (CrPC).
Despite these evidentiary gaps, in 2014, the trial court convicted both men — sentencing Putai to death and Dileep to life imprisonment. In October 2018, the Allahabad High Court upheld these convictions.
Appeal Before the Supreme Court
Aggrieved by the verdicts, the convicts approached the Supreme Court, arguing that the case was built entirely on circumstantial evidence and suspicion, not proof.
They stressed that:
- The DNA report was inconclusive, and the supplementary report was inadmissible.
- Forensic evidence lacked proper chain of custody.
- No credible witnesses or direct evidence established their involvement.
The State of Uttar Pradesh, however, defended the convictions. It argued that the witnesses were “simple villagers” with no reason to falsely implicate the accused. It further relied on the recovery of the victim’s belongings from a field allegedly cultivated by one of the accused, contending that this created a presumption under Section 106 of the Indian Evidence Act, which the accused failed to rebut.
Supreme Court’s Observations
After examining the evidence, the Supreme Court held that the prosecution had failed to establish a complete chain of circumstances pointing exclusively to the guilt of the accused.
The Bench made several critical observations:
- Failure of Investigation
- The Court described the probe as “lackluster and shabby”, emphasizing that the failure of police and prosecutors had caused the collapse of the case.
- Circumstantial Evidence Standard
- When a case is based purely on circumstantial evidence, the prosecution must prove guilt beyond reasonable doubt. The circumstances must be consistent, unbroken, and exclude any hypothesis of innocence.
- Forensic Evidence Lapses
- The Court noted grave lapses in forensic handling:
- Chain of custody of biological samples was not proved.
- No records were exhibited regarding storage or transmission of samples.
- Medical testimony was inconsistent on the number of samples collected.
- Suspicion Cannot Replace Proof
- The Court reiterated that however strong suspicion may be, it cannot substitute legal proof in criminal trials.
The Bench concluded:
“We have no hesitation in holding that other than the allegation that the child victim’s belongings were found in the accused’s field, the prosecution has failed to lead any credible evidence which can be considered incriminating. The prosecution fell woefully short of proving the guilt of the accused beyond all manner of doubt.”
Verdict: Acquittal of Both Accused
Given these findings, the Supreme Court set aside the convictions and sentences of both men. The death penalty imposed on Putai and life imprisonment given to Dileep were quashed.
The acquittal underscores the judiciary’s commitment to ensuring that innocent individuals are not punished in the absence of credible evidence, even in cases involving heinous crimes.
Representation
- For the Accused: Senior Advocate Shadan Farasat with Advocates Shreya Rastogi, Manasa Ramakrishna, Abhishek Babbar, and Kabir Dixit.
- For the State: Advocates Shaurya Sahay, Aditya Kumar, and Aman Jaiswal.
Key Takeaways
- Importance of Forensic Integrity
- Courts rely heavily on forensic science, but improper handling, missing chain of custody, or lack of expert testimony can render such evidence unreliable.
- Burden of Proof in Circumstantial Cases
- The prosecution must establish an unbroken chain of circumstances that points exclusively to the guilt of the accused.
- Suspicion is Not Proof
- Even in heinous crimes, convictions cannot rest on suspicion alone. Proof beyond reasonable doubt is the cornerstone of criminal jurisprudence.
- Need for Police Reforms
- The judgment highlights systemic issues in police investigations and trial procedures that often compromise justice.
Conclusion
The Supreme Court’s decision in Putai vs. State of Uttar Pradesh is a sobering reminder of the dangers of flawed investigations in criminal cases. While the brutal rape and murder of the 12-year-old remains a tragedy, the Court emphasized that justice cannot be secured by punishing individuals on the basis of weak, inconsistent, or procedurally flawed evidence.
The ruling also underscores the urgent need for better police training, stricter adherence to forensic protocols, and accountability mechanisms to prevent such miscarriages of justice in the future.
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