Revisiting the Burden of Proof: The Acquittal in Chandrabhan Sudam Sanap v. The State of Maharashtra

On January 28, 2025, the Supreme Court of India delivered a landmark judgment in Chandrabhan Sudam Sanap v. The State of Maharashtra, acquitting a man who had previously been sentenced to death for rape and murder. The Court's decision hinged on the necessity of electronic evidence certification, bringing to the forefront crucial discussions about evidentiary standards, due process, and the intersection of technology with criminal justice.

The Case and Its Controversies
The case involved the brutal rape and murder of a young woman, an incident that had sparked public outrage and demands for the harshest punishment. The trial court, and later the high court, sentenced Chandrabhan Sudam Sanap to death, largely relying on electronic evidence, including CCTV footage, mobile tower location records, and forensic digital footprints. However, the Supreme Court’s re-evaluation of the case exposed significant lapses in the manner in which this electronic evidence was presented and authenticated.

The judgment emphasized the requirement under Section 65B of the Indian Evidence Act, 1872, which mandates proper certification of electronic records for them to be admissible as evidence. The Court noted that the prosecution had failed to meet this critical standard, leading to concerns about the integrity and reliability of the evidence used to convict the accused.

A Precedent for Judicial Scrutiny of Digital Evidence
The ruling is a significant reaffirmation of the principle that procedural safeguards cannot be ignored, even in cases of heinous crimes. While electronic evidence has become a vital tool in criminal investigations, its admissibility must adhere to strict legal requirements to prevent wrongful convictions.
 

This case underscores the need for:

• Rigorous compliance with evidentiary laws: Law enforcement agencies must ensure that electronic evidence is properly authenticated before presenting it in court.
• Enhanced forensic capabilities: The case highlights the necessity for trained forensic experts to handle and certify digital evidence.
• Balanced jurisprudence: Courts must strike a balance between ensuring justice for victims and upholding the fundamental rights of the accused.

Implications for the Criminal Justice System

The verdict serves as a cautionary tale against over-reliance on technology-driven evidence without adequate legal safeguards. It also raises critical questions:

• Should procedural lapses in electronic evidence result in outright acquittals, or should there be provisions for rectification during trial?
• Is the existing legal framework equipped to handle the complexities of digital forensics in criminal cases?
• How can investigative agencies be trained to ensure compliance with evidentiary laws without compromising the pursuit of justice?

Conclusion
The acquittal in Chandrabhan Sudam Sanap v. The State of Maharashtra is a watershed moment in Indian jurisprudence, compelling stakeholders to reassess the role of electronic evidence in the legal system. While the decision upholds due process, it also serves as a stark reminder of the fine line between ensuring justice and the possibility of wrongful convictions due to procedural missteps. Going forward, this case may well become a reference point in shaping reforms for digital evidence management in India’s criminal justice system.