Introduction:

The Punjab and Haryana High Court, in the case Yatender Pal v. State of Haryana, has held that self-incriminatory statements made by an accused during a lie-detector test cannot be used as material evidence against them in a trial. A division bench of Justice Gurvinder Singh Gill and Justice Jasjit Singh Bedi clarified that a lie-detector test is merely an investigative aid and does not constitute admissible evidence unless corroborated by independent facts. The ruling came while acquitting Dr Yatender Pal, who was convicted under Section 302 IPC for the murder of his colleague, Dr Harsh Soni, and sentenced to life imprisonment. The prosecution alleged that Dr Yatender Pal had drugged the complainant and the deceased, later strangling Dr. Harsh Soni and placing his body in the complainant’s room. The prosecution primarily relied on circumstantial evidence, an extrajudicial confession allegedly made by the accused to the complainant, and forensic findings from the post-mortem report. However, the High Court found that the evidence presented by the prosecution was riddled with inconsistencies, particularly concerning the absence of a medical examination of the complainant, the delay in discovering the body, and the lack of direct proof connecting the accused to the crime. The Court also noted that refusal to undergo a lie-detector test cannot be used as a missing link in the chain of circumstantial evidence. It held that the prosecution failed to establish an unbroken sequence of events leading to the guilt of the accused and, thus, acquitted Dr Yatender Pal.

Arguments of Both Sides:

The prosecution contended that DDrYatender Pal had a strong motive for murdering Dr Harsh Soni as the latter allegedly teased him by calling names, causing humiliation. It was argued that on the night of the incident, Dr Pal had intoxicated both the complainant and the deceased, subsequently strangling DDrSoni and shifting his body into the complainant’s room. The prosecution relied heavily on the extra-judicial confession purportedly made by the accused to the complainant. Additionally, the prosecution highlighted the recovery of a rope and the deceased’s wallet from DDrPal, arguing that this linked him to the crime.

The defence, on the other hand, argued that the entire case was based on weak circumstantial evidence and an uncorroborated confession. It pointed out that the complainant himself had a vested interest in shifting the blame to Dr Pal, as he needed to justify how the deceased’s body ended up in his room. The defence also challenged the prosecution’s motive theory, stating that being teased was not a strong enough reason for a premeditated murder. Additionally, the defense questioned the reliability of the last-seen evidence, highlighting the nine-to-ten-hour gap between when the deceased was last seen with the accused and when his body was discovered. It also emphasised that a lie-detector test requires the accused’s consent, and refusal to undergo such a test should not be construed as evidence of guilt.

Court’s Judgment:

The Court found several inconsistencies in the prosecution’s case. It observed that the complainant’s testimony appeared self-serving, as he had to explain why the body of the deceased was found in his room. The Court held that an extra-judicial confession is inherently weak evidence and requires strong corroboration, which was missing in this case. It also pointed out that the alleged motive—that the accused was being teased—was speculative and insufficient to establish intent to commit murder.

The Court critically analysed the ‘last-seen’ theory and ruled that merely being seen together hours before the crime does not conclusively prove the accused’s involvement. It also rejected the prosecution’s reliance on recovered items, stating that it was unreasonable to believe that the accused would retain the rope used for strangulation and the deceased’s wallet instead of disposing of them. The Court further underscored that forensic evidence did not conclusively point to the accused, and the missing medical examination of the complainant created a significant gap in the chain of events.

Regarding the lie-detector test, the Court reaffirmed that such tests are merely investigative tools and that self-incriminatory statements obtained through them cannot be used as substantive evidence in court. It also emphasised that refusal to undergo the test does not equate to an admission of guilt or a missing link in circumstantial evidence.

In light of these findings, the Court set aside the conviction and acquitted Dr. Yatender Pal of all charges. The decision reaffirmed the principle that criminal convictions must be based on clear and convincing evidence and not on assumptions, speculative motives, or weak circumstantial inferences.