“Six Years Erased from a Man’s Life”: Supreme Court Orders ₹6 Lakh Compensation After Undertrial’s Acquittal, Condemns UP Police Investigation

Case Name: Arun @ Deepak v. State of U.P.

Date of Judgment: 26 October 2026

Citation: 2026 INSC 1150

Bench: Justice J.B. Pardiwala and Justice K. Vinod Chandran

Held: The Supreme Court directed the State of Uttar Pradesh to pay ₹6 lakh to a man who spent approximately six years in custody as an undertrial before being acquitted in a kidnapping and murder case. Condemning the investigation and prosecution, the Court found that the case against him had been built on surmises and conjectures without even a rudimentary investigation. The Court emphasised that investigating and prosecuting agencies are stakeholders in the justice delivery system and must seek justice for the accused as well as the victim and complainant.

Summary: The petitioner, Arun @ Deepak, approached the Supreme Court seeking bail after remaining in custody since November 2019 in a case registered under Sections 364, 302 and 201 of the Indian Penal Code, 1860. The prosecution case concerned the alleged kidnapping and murder of a man who had gone missing in Agra.

On 23 March 2026, noting the prolonged custody and that the case rested entirely on circumstantial evidence, the Supreme Court directed the trial court to complete the trial within three months. The trial concluded in the petitioner’s acquittal. After examining the translated trial court judgment, the Supreme Court reviewed the manner in which the investigation and prosecution had been conducted.

The Court noted that the petitioner was not named in the FIR or in the relevant statement recorded under Section 161 CrPC. He was implicated on the basis of CCTV footage and a co-accused’s confession. The trial court found that the CCTV footage was unclear and did not establish the identity of the persons seen on the motorcycle. The CCTV footage and call-detail records were also not supported by the certificate required under Section 65B of the Indian Evidence Act, 1872.

The prosecution had relied on the recovery of charred bones, but the forensic examination result was not produced at trial and no attempt was made to obtain the complainant father’s DNA sample to establish whether the remains belonged to his missing son. The medical evidence did not establish the cause or time of death. The Court also pointed to the failure to prove the alleged recoveries in accordance with the prosecution’s case, including the absence of a recorded statement concerning concealment and evidence that the accused had led the police to the recovered articles.

The Supreme Court further noted that the alleged demand for ₹50 lakh ransom had not been reported to the police and was spoken of by the complainant for the first time in court. The prosecution had examined only six witnesses, and the trial court found that none of the four circumstances relied upon by the prosecution had been proved

Describing the investigation as “slipshod” and the prosecution as “haphazard,” the Court observed that the investigating agency had also taken no steps to expedite the petitioner’s trial. It stated that the police and prosecution must recognise their responsibility to protect the rights of an accused person, who is presumed innocent until proven guilty. A copy of the judgment was directed to be sent to the Director General of Police and the Home Secretary of Uttar Pradesh.

Decision: The Supreme Court disposed of the special leave petition and directed the State of Uttar Pradesh to pay the petitioner ₹6 lakh within one month. If payment is not made within that period, the amount will carry interest at 18% per annum.