In a significant ruling, the High Court of Uttarakhand at Nainital overturned rape convictions of two men, highlighting gaps in forensic evidence handling and emphasizing that suspicion cannot replace proof in criminal trials.
Background of the Case
The case arose from a 2018 incident in Haldwani, where a young woman with intellectual disability went missing and was later found in a distressed condition. Her family alleged that she had been physically and sexually assaulted.
The trial court had convicted the accused, Mool Chandra and Bhup Singh, under multiple provisions of the Indian Penal Code, including rape and kidnapping, sentencing them to rigorous imprisonment.
The Division Bench closely examined medical, forensic, and electronic evidence presented during trial.
The Court noted that the medical report did not conclusively establish rape.
“No definite opinion regarding rape could be given,” the judgment recorded, though the possibility was not ruled out.
A major focus was on forensic evidence. While certain exhibits indicated the presence of biological material, the Court found serious gaps in how these samples were collected, stored, and documented.
“The evidentiary value of forensic material… rests equally upon the sanctity and continuity of the chain of custody,” the bench observed, stressing that any break in this chain weakens reliability.
The Court found that key procedural safeguards such as proper seizure records and documentation were missing, creating doubt about the integrity of the evidence.
For Bhup Singh, the prosecution relied heavily on forensic linkage. However, the Court held that the absence of a clearly proven chain of custody meant that the forensic evidence could not be treated as conclusive.
“Conviction must rest on legally proved evidence and not on suspicion, however strong,” the Court stated while extending the benefit of doubt.
In contrast, Mool Chandra’s case rested on circumstantial evidence, including CCTV footage showing him accompanying the victim and call detail records placing him near the location.
However, the Court found no scientific evidence linking him to sexual assault. It held that “presence or proximity cannot substitute for proof” of such a serious offence.
At the same time, the Court concluded that he had taken the victim who was unable to make independent decisions due to intellectual disability away from lawful guardianship, thereby committing kidnapping.
Allowing the appeal of Bhup Singh, the Court set aside his conviction under rape provisions and ordered his release, subject to legal formalities.
Mool Chandra’s appeal was partly allowed. His convictions for rape and related offences were set aside, but his conviction under Section 363 IPC (kidnapping) was upheld. Since he had already served over four years in custody, the Court directed his release.
Case Details
Case Title: Mool Chandra @ Moola vs State of Uttarakhand & Bhup Singh @ Bhupali vs State
Case Number: Criminal Appeal No. 143 of 2019 & Criminal Jail Appeal No. 11 of 2019
Judges: Justice Ravindra Maithani & Justice Ashish Naithani
Decision Date: 12 February 2026
