The wrongful convictions can be a result of bypassing the investigatory steps, unreliable forensic evidence, and uncorroborated testimonies. The judgment highlights the urgent need to bridge gaps in investigatory practices and ensure consistent application of the ‘Five Golden Principles of Circumstantial Evidence’.
On August 20, 2025, a two-judge bench, headed by Justice Prashant Kumar Mishra and Justice Augustine George Masih, delivered a corrective ruling in ‘Neelam Kumari v. The State of Himanchal Pradesh’. The ruling not only preserves individual liberty but also paves the way for improved investigation and forensic practices, thereby enhancing trust in judicial fairness.
The appellant, Neelam Kumari, was convicted by the trial court for the murder of her infant son and was sentenced to life imprisonment. The High Court upheld the conviction, after which she appealed to the Supreme Court. The prosecution’s case relied on three main points: alleged extra-judicial confessions to her husband and villagers, the use of a dupatta as the weapon, and forensic reports claiming blood and tissue were found on it.
In her defence, Neelam Kumari argued that her child had suddenly stopped responding and that she had sought medical help. She also pointed to strained family relations and threats from her husband’s first wife, which she claimed were overlooked in the case.
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The Supreme Court, after closely examining the details of the case, held that the case against Neelam Kumari lacked evidentiary strength. The judgment stressed the need for caution in relying on confessions, reiterating that independent corroboration is essential before such statements can form the basis of conviction. Citing precedents like Sahadevan v. State of Tamil Nadu and Chandrapal v. State of Chhattisgarh, the Court reaffirmed that extra-judicial confessions are inherently weak forms of evidence.
On the forensic side, while the dupatta allegedly carried blood and human tissue, the post-mortem doctor was never consulted to confirm whether these matched the child’s injuries. These breaks in the evidentiary chain, the Court ruled, left the forensic traces vague and unreliable.
Moreover, several inconsistencies were found in the theory of deliberately throttling the infant. Neelam Kumari’s attempt to seek medical help and her lack of concealment did not align with the allegation of intentional murder. The timeline was further weakened by conflicting witness accounts of her whereabouts. In the absence of a clear motive, the Court held that circumstantial evidence should weigh in favor of the accused.
Building on these findings, the Court ruled that the prosecution had not proved that the accused was guilty ‘beyond a reasonable doubt’ of the charge presented, and thus, set aside the conviction under Section 302 of the Indian Penal Code (IPC), acquitting the appellant. At the same time, the ruling carried a broader message: judicial safeguards against wrongful convictions must be reinforced by administrative measures such as training, standard operating procedures, and forensic protocols to prevent repetition of such lapses. In this light, the judgment has highlighted several systemic gaps that require urgent attention for better delivery of criminal justice and in the interest of citizens:
- Insistence on the reasoned findings and high standards of proof: In the circumstantial cases, the court has fortified safeguards against wrongful convictions to protect accused persons, particularly the economically and socially vulnerable. There is also a need for time-bound investigations and consistent supervisory sign-offs to prevent casual collection of evidence. This ensures stronger protection for individual liberty and human dignity, where a criminal conviction cannot rest on suspicion, loose inference, or shoddy evidence.
- Better forensic practices: The court has implied the need for upgrading police forensic procedures, including written documentation of an unbroken chain of custody for collected biological samples and weapons, and greater involvement of post-mortem doctors in examining them. Moreover, quarterly audits of the forensic labs can ensure adherence to proper handling, repositing, and reporting techniques so that the evidence remains admissible and probative.
- Unreliability on inconsistent community testimony: The court has curbed overreliance on uncorroborated and inconsistent community testimony, which is often interest-driven. Prosecutorial directions may still render extra-judicial confessions admissible, but their evidentiary value must remain weak.
- Capacity-building and Investments: The ruling also calls for capacity-building and training of the investigators, police, and forensic officials to handle cases of infant death with due diligence. This ensures a balanced inquiry while protecting the accused against wrongful prosecution. Moreover, the state should allocate sufficient funds to forensic labs, for training officials, cold-chain storage, audit trails, and medical infrastructure. This leads to greater transparency as the evidence will be reliable and unfabricated, thereby boosting public confidence in the criminal justice system.
Thus, the judgments, like those given in Neelam Kumari v. the State of Himachal Pradesh, highlight the urgent need to bridge gaps in investigatory practices. The wrongful convictions can be a result of bypassing the investigatory steps, unreliable forensic evidence, and uncorroborated testimonies. To protect the citizens from such setbacks in the justice delivery mechanism, the court rulings must deter negligence in the investigation, rely on documentation, caution analysis of the uncorroborated extra-judicial confessions, inculcate an evidentiary gateway by the trial court, and ensure consistent application of the ‘Five Golden Principles of Circumstantial Evidence’.
If these rulings are implemented through targeted reforms and coordination among institutions at the micro, meso, and macro levels, India’s criminal justice system can evolve into one that is both rigorous and humane.
Anshal Telang is a TRIP intern.
Edited and Mentored by Sneha Yadav.
References:
Neelam Kumari v. The State of Himachal Pradesh, Supreme Court of India, Criminal Appellate Jurisdiction, Criminal Appeal No. 582 of 2013.
https://api.sci.gov.in/supremecourt/2010/26764/26764_2010_16_1501_63402_Judgement_20-Aug-2025.pdf
Ghosh, S. (2025). After Supreme Court rap, Jharkhand HC decides 75 criminals appeals in a week. The Indian Express.
Chandrawat, S. (2025). Supreme Court’s 2025 Action Plan: Tackling 7.24 Lakh Criminals Appeals Across High Courts. Chandrawat & Partners.
Y, S. (2025). Supreme Court Urges High Courts to Use AI, Digitisation, and Registrar Appointments to Reduce Over 7 Lakh Criminal Appeal Backlog. Court Book.
Rathore, R. (2025). Soft Copy of Trial Court Record to be Automatically Called for By Registry: Supreme Court On Reducing Pendency Of Criminals Appeals. Verdictum.
About the author
Anshal Telang, a student of Master of Arts in Public Policy and Law at the Tata Institute of Social Sciences, Mumbai is currently pursuing internship under TRIP.
Sneha Yadav is an electronics engineer with post graduation in political science by qualification. Sneha has wide-ranging interests in the contemporary social, economic, administrative and political issues of India.
