Santosh Kumar Singh v. State Through 2010

Parties Involved

• Petitioner / Appellant- 

Name of the petitioner and Accused before the Supreme court a 24-year-old final- year law student Santosh Kumar Singh is the law at Delhi University (Faculty of law) passing LL. B from the university of Delhi campus Law center in December 1994. Son of an IPS officer J.P Singh who eventually retired as a joint Commissioner serving in Delhi Police at that time.  On 23 January 1996, he rapped and murdered the victim at her residence in Vasant Kunj, New Delhi. 

• Respondent / Victim 

Name of the Victim and Respondent before the Supreme Court, a 25-year-old law student of 3rd year at Delhi University Priyadarshini Mattoo came from Kashmir Pandit Family residing in Vasant Kunj, New Delhi. Her Father Shri Chaman Lal Mattoo is a retired chief engineer from ALL India Radio (AIR) and her

mother Mrs. Sumitra Mattoo. She was repeatedly stalked and harassed by the accused and due to this she also had complained to higher authorities about Santosh Kumar Singh. Despite these all complaints no major action was taken due to the Santosh father background. On 23 January 1996, she found raped and murdered in her house. 

Abstract

Priyadarshini Matto, a 25-year-old, was found raped and murdered in her residence at New Delhi on January 23, 1996. A charge sheet was filed by CBI in which Santosh Kumar Singh was the name of the accused. After Few months trail against Santosh started before an additional session judge. Santosh Singh was finally acquitted in 1999 by an additional session judge after two long years. The Delhi High court accepted the CBI report the next year, where justice was delivered after six years of fighting. Santosh Kumar Singh was found guilty by the High Court and given capital punishment. Santosh Kumar Singh challenged the order of High Court in the Supreme Court. By the Supreme Court the capital punishment was changed to life in prison, but the Supreme Court upheld Santosh Kumar Singh conviction. 

Introduction

The case of Priyadarshini Mattoo case was one of the most shocking and tragic examples of sexual violence in Indian Legal History, where a 25-year-old law student was brutally raped and murdered by her senior. Rape is a sexual assault without victim’s consent. The IPC Section 354 punishes accused of Rape Cases by imposing a maximum 2-year jail sentence for any attack or use of unlawful force on a woman. Due to the increase in terrorist attack in the Kashmir, they shifted towards Jammu. From Jammu she completed her B.com from MAM College. To pursue M.com and LLB she came to Delhi University. She usually stayed in her relatives house but afterwards her father joins a nonprofitable organization as an chairman in Delhi and the whole family were shifted in Vasant Kunj. Santosh Kumar Singh, final year law student at Delhi University passing LLB from the Campus Law center in December 1994, fell in love with her junior Priyadarshini. She is rejecting the proposals he made to her. By this Santosh started stalking and harassing her repeatedly and due to this her family filed a police complaint against him and she was given an escort for a while. On 23 January 1996 she found dead in her own residence and was brutally raped and murdered. She was hit 14 times from the helmet after being raped. Then a wire was used to strangle her neck. Santosh Kumar Singh came up as a primary suspect in this case when the CBI started investigation of the cases and asked the neighbor about the incident. The fight for Justice started. 

Facts of the Case- 

Priyadarshini Matto was a law student at Delhi University and was living with their parents at Vasant Kunj. 

Santosh Kumar Singh was a senior of hers and a final year law student in the Delhi University from the same Campus Law Center in December 1994. The accused got to know about the victim while he was a student at Campus Law Center. He also had a black bullet motorcycle with the number DLI SG 1122. When the victim rejects his proposal, the accused started stalking and harassing her. 

The Victim by repeatedly requesting him to don’t follow him but the appellant continued to harass and threaten her. Then she filed multiple complaints in multiple Police Stations. Finally, on 23.1.1996, a Personal Security Officer Head Constable Rajinder Singh failed to arrive on time in her department on time. As a result, the victim’s parents were not in their house because they had to appear at Tis Hazari Courts for a civil case. Due to the absence of their parents on 23 January 1996 the victim was alone at her home in Vasant Kunj, New Delhi, the accused illegally entered in her house, brutally raped her and murdered by him.  She het continuously 14 times by the helmet and then strangled her with an electric wire to death.  By the postmortem it was confirmed that she was brutally raped, physically assault, and murdered. Although there were no bite marks on her face and body and forensic samples such as semen, hair, and blood were collected. The CBI tool over the case. Despite the strong evidence, the Trial Court (Additional Sessions Judge, Delhi) on 3 December 1999 the accused, claiming “lack of evidence”. The CBI bring the cases Infront of Delhi High Court. The Court found Santosh Kumar Singh guilty of Rape and Murdered and sentenced him Death Penalty. Then afterwards Santosh Kumar appeals to the apex court of India to challenge the Delhi High Court judgement. On the 6 October the Supreme Court of India, under the judgement of justice H.S. Bedi and C.K. Prasad, upheld the conviction of Santosh Kumar for rape and murder but reduced his sentence from death penalty to life imprisonment holding that the cases did not falls under the “rarest of rare” category. 

Issue raised- 

• Whether the investigation done by CBI was fair and proper?
• Whether DNA fingerprints simply proved beyond a reasonable drought that Santosh was guilty?
• Whether the accused’s guilt and the circumstantial evidence can be shown beyond a reasonable doubt before he may be found guilty of the crime committed?

Argument of the Parties- 

• Argument by Applicant (CBI and prosecution)- The Accused Santosh Kumar Singh had a clear motive and intention because he was very obsessed with Priyadarshini and continuously stalked and harassed her earlier. The postmortem evidence and the DNA test also proved the involvement of accused in the rape and murdered. Although the trial court ignored the relevant fact and evidence and gave accused benefit of doubt. The prosecution argued that this was a gruesome and planned crime with the appropriate intension and motive, it deserved to get Capital Punishment. 
• Argument by the Respondent side (accused)- The accused Santosh Kumar Singh denied all the charges, claiming he was falsely implication by the CBI. He questions the fairness and improper investigation by the CBI. He also said that the forensic evidence was mishandled and temper during the time of investigation. They stated that the capital punishment was too harsh and not justified under the rarest of rare category.

Related Provision

• Indian Penal Code–  

•  Section 302 -punishment for murder
• Section 376 – punishment for rape 
•  Section 354 – assault or physical force against a woman with the intention of outrage her modesty 

The Indian Evidence Act, 1872

Section 6: – Regardless of whether they happened at the same time and location or at different times and locations, facts that, while not in dispute, are sufficiently related to a fact in dispute to form a component of the same transaction are significant. 

Judgement 

• In the Trial Court- The court acquitted the accused by saying that there was suspicion but not clear evidence or proof to convict. The Court mentioned that the accused can “might be guilty”, but benefit of doubt was given. 
• In the High Court – When the case was appealed in the High Court, in which the court reversed the decision of Trial Court and sentenced the accused capital punishment. Santosh Kumar Singh found guilty of rape and murder under section 376 and 302 of the Indian Penal Code by the Delhi High Court on October 17, 2006 and was given death penalty. The Court also criticized Delhi Police slowness and prejudice in assisting Mattoo after she filed a complaint against Singh as his father; J.P. Singh was the then-senior IPS officer and Director General of the Delhi Police at the time. The High Court convicted Santosh Singh and he was awarded the death penalty. 
• In the Supreme Court- Santosh Kumar Singh challenged the Delhi High Court judgement. In which the apex court put a stay in the High Court Judgement. The court issued a notice to CBI on an appeal filed by the convict against the high court judgement. In October 2010, the Supreme Court convicted the accused but reduces the punishment from capital punishment to life imprisonment as it was not justified under “rarest of rare” category. 

Conclusion-

Rule of Law is not intended for individuals who uphold the law or their close family members. Isn’t this strategy teaching the kids of those with access to the legal system that they, too, may break the law without consequence. Why shouldn’t those who establish laws consider the need for a system that is free from bias and independent of those who uphold justice when someone commits a crime.