Case Note: Dr. Sunil Clifford Daniel Vs. State Of Punjab [(2012) 11 SCC 205]
- IJLLR Journal
- May 19, 2024
- 1 min read
Omkar Bhalerao, Maharashtra National Law University, Aurangabad
ABSTRACT
In this landmark judgment, the Supreme Court of India addressed the interplay between Section 162(1) of the Code of Criminal Procedure (CrPC) and Section 27 of the Indian Evidence Act, 1872. The case involved the conviction of Dr. Sunil Clifford Daniel, a qualified doctor, for the murder of his wife, Dr. Loyalla Shagoufta. The court emphasized that circumstantial evidence must form a complete chain, leading to an inescapable conclusion of guilt. It clarified the admissibility of information obtained from an accused person during police custody under Section 27, even when statements made to the police are restricted by Section 162(1). The judgment continues to influence how courts interpret evidence in criminal trials, emphasizing the need for rigorous evaluation and adherence to legal provisions.
Keywords: Circumstantial Evidence, Presumption of Innocence, Motive, Absence of Direct Proof, Inconsistencies in Statements, Sec. 27 of IEA, Sec. 162(1) of CrPC
