The Punjab and Haryana High Court has set aside the conviction of Satnam Singh and Balwinder Singh in a case concerning the disappearance of a judicial file from a court in Gurdaspur, holding that the prosecution failed to establish their guilt beyond reasonable doubt.
Justice Mandeep Pannu delivered the judgment on August 26, 2026, allowing both revision petitions. The Court found that the lower courts had relied too heavily on circumstances that created suspicion but did not form a complete and reliable chain of evidence.
Background of the Case
The matter arose after a judicial file relating to a pending criminal case went missing from the Court of the Chief Judicial Magistrate, Gurdaspur, in June 2000. The missing record concerned a case arising from an FIR alleging offences under Sections 420, 467, 468 and 471 of the IPC.
The trial court convicted four accused under Section 380 IPC and later the appellate court upheld the conviction while enhancing the sentence. The appellate court also found them liable under Section 201 IPC, which deals with causing disappearance of evidence or giving false information to screen an offender.
Satnam Singh and Balwinder Singh challenged the findings before the High Court. Darshan Singh died during the proceedings, and the revision petition concerning him had already abated.
High Court's Observation
The High Court closely examined the prosecution evidence. It noted that the witness relied upon to establish the alleged burning of the file did not support the prosecution and denied making the statement attributed to him.
The Court also found that an alleged extra-judicial confession had not been proved through the person before whom it was supposedly made. According to the judgment, this left a significant gap in the prosecution's case.
Regarding Balwinder Singh, the Court found that no specific act connecting him with the removal or destruction of the file had been established.
“Suspicion, however strong, cannot take the place of proof.”
The Court stressed that proving that a judicial file disappeared was different from proving who removed it, who participated in the alleged plan and whether the file was subsequently destroyed. Each link had to be established beyond reasonable doubt.
Decision
The High Court allowed both revision petitions and set aside the conviction and sentences imposed by the trial court and modified by the appellate court.
Satnam Singh, through his legal representative, and Balwinder Singh were acquitted of the charges under Sections 380 and 201 IPC.
The revision concerning Darshan Singh remained abated due to his death.
