By Binay Kumar, Advocate-on-Record, Supreme Court of India; Managing Partner, The Justice Law Partners.
Case: Arun @ Deepak v. State of Uttar Pradesh
Decision: 26 October 2026
Case No.: SLP (Crl.) No. 4859/2026
Neutral citation: 2026 INSC 1150
Bench: J. B. Pardiwala and K. Vinod Chandran, JJ.
Judgment authored by: K. Vinod Chandran, J.
Reportability: Reportable
Relevant paragraphs: 11–17
The issue
The Supreme Court examined the consequences of an investigation that left an accused in custody for approximately six years before his acquittal. The matter had reached the Court through a bail petition. On examining the record following acquittal, the Court considered whether the failures of investigation warranted reparation.
The evidentiary failures
The prosecution case depended on circumstantial evidence. The CCTV footage and call-detail records were not supported by the requisite certificate under Section 65B of the Indian Evidence Act, 1872. The recovered bones had not been reliably identified by the forensic steps necessary on the facts. The alleged recoveries were not supported by the required disclosure evidence, and the purported last-seen theory was not established.
The order
The Court directed Uttar Pradesh to pay ₹6 lakh to the petitioner within one month, with interest at 18% per annum in the event of default. It also directed that the judgment be communicated to senior State authorities. The conclusion followed the Court’s assessment of the particular investigation and the prolonged deprivation of liberty.
The legal significance
Investigating and prosecuting agencies owe duties to the administration of justice and to the accused, who remains presumed innocent. A defective investigation can have constitutional consequences. But this judgment should not be read as establishing an automatic right to compensation whenever an accused is acquitted.
Practice point
In prolonged undertrial cases, counsel should examine the custody history, foundational electronic-evidence requirements, chain of custody, recovery evidence, and forensic identification rather than treating each alleged circumstance in isolation.
Judgment and editorial note
Supreme Court official judgment entry. This case note is an explanatory summary of the decision and is not legal advice. The operative judgment governs in the event of any discrepancy.