Punjab & Haryana High Court Declines to Interfere with Acquittal in Poisoning Case; Holds Prosecution Evidence Unreliable and Medical Evidence Contradictory
Case Name: Surjit Kaur v. State of Punjab and Others
Date of Judgment: 12 January 2026
Citation: CRA-D-531-DBA of 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 complainant’s appeal against acquittal and upheld the judgment of the trial court, holding that the prosecution had failed to prove its case beyond reasonable doubt. The Court held that in an appeal against acquittal, interference is permissible only when the findings of the trial court are perverse or manifestly illegal. Where the view taken by the trial court is a plausible one based on appreciation of evidence, the acquittal cannot be set aside merely because another view is possible.
Summary: The appeal was filed by the complainant assailing the judgment passed by the Additional Sessions Judge (Adhoc), Patiala, whereby the respondents were acquitted of charges under Sections 302, 449, 148 and 149 IPC. The prosecution case was that on 11 November 1998, the respondents had forcibly administered poison to Labh Singh, husband of the complainant, by restraining him and putting poisonous substance into his mouth, resulting in his death during treatment at PGI Chandigarh.
The prosecution relied primarily on the testimonies of the complainant Surjit Kaur and Gurcharan Singh as eyewitnesses, medical evidence relating to poisoning, and the alleged dying declaration of the deceased. During trial, the defence examined senior police officers who deposed that the investigation, conducted pursuant to directions of the High Court, had revealed the allegations to be false and motivated by longstanding factional rivalry and prior litigation between the parties.
The High Court noted that the scope of interference in an appeal against acquittal is limited and reiterated settled principles laid down by the Supreme Court that an acquittal strengthens the presumption of innocence. Upon examination of the evidence, the Court found that the medical testimony did not support the prosecution version of forcible administration of poison. The post-mortem doctor had stated that there were no significant injuries on the body of the deceased and that the minor injury in the mouth could have occurred during medical treatment, such as gastric lavage.
The Court further held that the conduct of the alleged eyewitnesses was highly unnatural. According to the complainant’s own version, other witnesses reached the spot only after she raised an alarm, indicating that they had not actually witnessed the occurrence. The Court found it improbable that close relatives would remain passive spectators while poison was allegedly being forcibly administered. The presence of deep-seated enmity and party faction in the village further strengthened the possibility of false implication.
The Court also took note of the fact that the investigation had been verified by a senior police officer, who found the allegations to be false after associating both sides. The findings of the trial court were found to be based on proper appreciation of evidence and not suffering from any perversity or illegality.
Decision: The appeal was dismissed. The judgment of acquittal passed by the trial court was affirmed. All pending applications were disposed of, and the records were directed to be returned to the court below.