Punjab & Haryana High Court Upholds Murder Conviction Based on Circumstantial Evidence and Firearm Recovery; Affirms Life Sentence

Case Name: Surajmal v. State of Haryana

Date of Judgment: 12 January 2026

Citation: CRA-D-1539-DB-2015

Bench: Hon’ble Mrs. Justice Lisa Gill and Hon’ble Mrs. Justice Meenakshi I. Mehta

Held: The Punjab and Haryana High Court dismissed the criminal appeal and upheld the conviction and sentence of the appellant under Sections 302 and 449 of the Indian Penal Code and Section 25 of the Arms Act. The Court held that the prosecution had successfully established a complete chain of circumstantial evidence, including last-seen circumstances, motive, recovery of the firearm at the instance of the accused, and medical evidence, which conclusively proved the guilt of the appellant beyond reasonable doubt.

Summary: The appeal was filed challenging the judgment dated 22 September 2015 passed by the Sessions Judge, Rohtak, whereby the appellant was convicted for murder, house trespass and unlawful possession of a firearm. The prosecution case arose from the intervening night of 1/2 December 2014, when Naveen was shot dead inside his house at village Mayna, District Rohtak.

As per the prosecution, information regarding the murder was received by SI Ramesh Chander on the morning of 2 December 2014. The complainant Parameet, brother of the deceased, stated that the appellant Surajmal, who was their uncle, had visited their house at about 8:00 PM on the night of occurrence and that Parameet had accompanied him to his house, where both slept. When Parameet returned home at about 6:00 AM, he found his brother Naveen lying dead on the cot with a firearm injury on his left temple.

During investigation, circumstances emerged indicating the appellant’s involvement. The prosecution relied upon the last-seen evidence, strained relations between the appellant and the deceased, recovery of the firearm pursuant to the disclosure statement of the appellant, and medical evidence which confirmed that death was caused due to a firearm injury.

The defence argued that the case was based purely on suspicion, that the last-seen theory was weak, that no independent witness had been examined, and that the chain of circumstances was incomplete. The High Court rejected these contentions, holding that the circumstantial evidence on record was consistent and formed an unbroken chain pointing only towards the guilt of the appellant.

The Court observed that motive, though not essential where other circumstances are proved, stood established. The recovery of the weapon of offence and corroborative medical evidence further strengthened the prosecution case. Minor discrepancies were held to be inconsequential and not affecting the core of the prosecution story.

Decision: The criminal appeal was dismissed. The conviction of the appellant under Sections 302 and 449 IPC and Section 25 of the Arms Act, along with the sentence of life imprisonment and other sentences imposed by the trial court, were affirmed.