Punjab & Haryana High Court Upholds Murder Conviction Based on Circumstantial Evidence; Holds ‘Last Seen’, Motive and Recovery Form Complete Chain

Case Name: Harnam Singh @ Ranjit Singh v. State of Haryana

Date of Judgment: 9 January 2026

Citation: CRA-D-987-DB-2004

Bench: Hon’ble Mr. Justice N.S. Shekhawat and Hon’ble Mrs. Justice Sukhvinder Kaur

Held: The Punjab and Haryana High Court dismissed the criminal appeal and upheld the conviction of the appellant under Section 302 IPC, holding that the prosecution had successfully established a complete chain of circumstantial evidence. The Court held that the “last seen” circumstance, coupled with proved motive, recovery of the blood-stained weapon at the instance of the accused, and corroborative medical evidence, conclusively established the guilt of the appellant beyond reasonable doubt.

Summary: The appellant challenged the judgment of conviction and order of sentence dated 9 October 2004 passed by the Sessions Judge, Ambala, whereby he was convicted for the murder of Baba Hari Om Giri, a priest residing in a Shiv Temple at Kala Amb. The prosecution case was that the appellant, who had earlier served as a priest in the same temple, bore animosity towards the deceased over his occupation of the temple and had threatened him shortly before the occurrence.

As per the prosecution, on the night of 9 September 2003, the appellant and the deceased were last seen together in the temple by witnesses Hem Raj and Dinesh Kumar. The next morning, the deceased was found lying in an injured condition with incised wounds on his face and neck and succumbed to injuries while being taken to the hospital. FIR was lodged promptly on the basis of suspicion arising from the appellant’s conduct and prior threats.

During investigation, the appellant was arrested and, pursuant to his disclosure statement, a blood-stained takua (sharp-edged weapon) was recovered from bushes near the Markanda river. The post-mortem report revealed two incised wounds, including a fatal injury to the cervical vertebra and spinal cord, sufficient to cause death in the ordinary course of nature. The doctor opined that the injuries could have been caused by the recovered weapon.

Before the High Court, the appellant contended that the case was based on incomplete circumstantial evidence, that the gap between the “last seen” circumstance and the death was substantial, that there were contradictions in witness testimonies, and that the serological report did not conclusively match the blood group. The State defended the conviction relying on consistent ocular testimony, proved motive, recovery of weapon and medical corroboration.

The Division Bench held that minor discrepancies regarding timing were natural and did not erode the core of the prosecution case. The Court observed that the witnesses were rustic villagers deposing after a long interval and their evidence consistently established that the appellant and the deceased stayed together in the temple on the night of occurrence. The motive arising from the appellant’s resentment against the deceased’s presence in the temple was clearly proved. Recovery of the blood-stained weapon at the appellant’s instance and medical opinion further strengthened the prosecution case.

The Court held that when all circumstances are taken together, they form an unbroken chain pointing only to the guilt of the accused and ruling out any hypothesis of innocence.

Decision: The criminal appeal was dismissed. The judgment of conviction and order of sentence passed by the Sessions Judge, Ambala, convicting the appellant under Section 302 IPC and sentencing him to life imprisonment, were affirmed.