Gurmeet Ram Rahim Acquitted in Journalist Murder Case, But Three Co-Accused Convicted: Punjab & Haryana High Court Upholds Life Imprisonment for Actual Shooters

"The Prosecution Was Not Able To Prove Its Case Against A1 Beyond Reasonable Doubt", In a landmark and closely watched criminal appeal arising from one of the most sensational murder cases in the history of Haryana, the Punjab and Haryana High Court on March 7, 2026 acquitted Dera Sacha Sauda chief Gurmeet Ram Rahim Singh of the charge of criminal conspiracy in the murder of journalist Ram Chander Chhatrapati, while simultaneously upholding the life imprisonment awarded to the three other convicted accused — the actual shooters and the supplier of the weapon.

A Division Bench of Chief Justice Sheel Nagu and Justice Vikram Aggarwal, speaking through Justice Vikram Aggarwal, set aside the conviction and sentence of Gurmeet Ram Rahim Singh (A1) recorded by the Special CBI Court at Panchkula on January 11, 2019, holding that the prosecution's case rested almost entirely on the evidence of a single witness whose testimony was riddled with inconsistencies, partisan conduct and a troubled history of resiling and reviving. The appeals of the other three convicts — Kuldeep Singh alias Kala (A2), Nirmal Singh (A3) and the legal representatives of the deceased Krishan Lal alias Kishan Lal (A4) — were dismissed and their convictions were upheld.

Background of the Case

On the night of October 24, 2002, Ram Chander Chhatrapati, editor of the Sirsa-based evening newspaper "Pura Sach," was shot at outside his house by two armed assailants who called him out of his home. His son Aridaman and elder son Anshul Chhatrapati were eyewitnesses. Aridaman's initial complaint named the assailants as "Kuldeep" and "Nirmal" — A2 and A3. A2 (Kuldeep Singh) was apprehended at the spot by patrolling policemen, while A3 managed to flee on a scooter. Ram Chander Chhatrapati succumbed to his gunshot injuries on November 21, 2002 at Apollo Hospital, Delhi.

A4, Krishan Lal, the Prabandhak (manager) of Dera Sacha Sauda, was alleged to be part of the conspiracy — he had supplied his licensed .32 bore revolver and a walkie-talkie set belonging to the Dera to the shooters. A1, Gurmeet Ram Rahim Singh, was the chief of the Dera and was alleged to have masterminded the killing on account of Chhatrapati's provocative publications about sexual exploitation of Sadhvis in the Dera.

The Haryana Police investigation was widely seen as defective and biased. Following petitions by Anshul Chhatrapati and suo motu proceedings by the High Court, investigation was transferred to the CBI in November 2003. The CBI filed a final report initially against A2, A3 and A4, and only named A1 in a supplementary charge sheet on July 30, 2007 — nearly five years after the incident — based on the statement of Khatta Singh, alleged to be A1's driver. The trial court convicted all four accused in January 2019, sentencing them to life imprisonment.

The core legal questions before the High Court were: whether the eyewitness testimony of the deceased's sons (PW3 and PW5) could sustain conviction of A2 and A3 despite being related witnesses; whether the involvement of A4 was proved given the use of his licensed weapon; and most critically, whether the sole testimony of Khatta Singh (PW31) — a witness who turned hostile during trial and was re-examined only after A1's conviction in a separate rape case in 2017 — was sufficient to prove criminal conspiracy against Gurmeet Ram Rahim Singh beyond reasonable doubt.

Court's Observations and Judgment

On Eyewitness Testimony of Related Witnesses

The Court firmly rejected the argument that the testimonies of PW3 Anshul Chhatrapati and PW5 Aridaman, being related to the deceased, deserved to be discarded or viewed with suspicion. Relying on the celebrated three-Judge Bench ruling in Dalip Singh v. State of Punjab (1953), the Court reiterated that the mere fact of relationship is "often a sure guarantee of truth" rather than a source of suspicion. The Court observed that the version given by Aridaman in the FIR was reiterated by him consistently in the witness box years later and could not be shattered in cross-examination — a finding equally applicable to the evidence of Anshul Chhatrapati.

"The statements of both PW3-Anshul Chhatrapati and PW5-Aridaman are completely consistent and trustworthy. They cannot be said to be parrot like statements though, when a truth is stated, it may appear to be a parrot like statement."

The Court was unimpressed by the defence argument that injuries were found both on the front and back of the deceased's body while the eyewitnesses stated he was shot from the front. It held that when shots are fired continuously, there is a "very high likelihood that some shots may hit on the front of the body and the remaining on the back side, when a person ducks or turns around."

On Minor Inconsistencies and Delayed Special Report to Magistrate

The Court extensively discussed the law on minor inconsistencies in evidence, holding that when a witness deposes in court after much time has elapsed from the incident, "inconsistencies are bound to be there." Applying the principle laid down in Yogesh Singh v. Mahabeer Singh (2016), the Court held that minor contradictions, insignificant embellishments or small omissions do not affect the core of the prosecution case. The delay in sending the special report to the Magistrate, the non-recording of the factum of A2 having been detained at the police post, and the absence of the time of arrest in the memo were brushed aside as instances of defective investigation that did not go to the root of the matter.

"Defective investigation, per se, would not enure to the benefit of the accused unless it goes to the root of the very case of the prosecution being fundamental in nature."

On Non-Conduct of Test Identification Parade

The Court rejected the argument that the non-holding of a Test Identification Parade was fatal to the prosecution's case. It held that from the very inception of the case, the names of A2 and A3 had surfaced — A2 was apprehended at the spot and had himself given his name as Kuldeep Singh. Relying on Dana Yadav v. State of Bihar (2002), the Court held that failure to hold a TIP does not make identification evidence inadmissible, and that in the present case, the identification in the witness box had ample corroboration from the earliest stages of the case.

On the Role of A4 and the Licensed Weapon

The Court held that the use of A4's licensed .32 bore revolver in the commission of the murder was conclusively established. The revolver had been recovered from A3 and its ownership was proved through documentary evidence including the arms licence bearing A4's name and address as resident of Dera Sacha Sauda. No explanation was offered by A4 as to how his weapon came into the possession of the assailants. The defence sought to counter this through the testimony of DW4-Nachhattar Pal, who claimed that some police officials had taken away A4's weapon on February 25, 2002. The Court dismissed this as an afterthought since A4 had not reported the matter to any authority, and there was "a major contradiction" between the versions of DW4-Nachhattar Pal and A4's own statement under Section 313 CrPC.

On Criminal Conspiracy — The Law

Before examining the role of A1, the Court set out the foundational principles governing criminal conspiracy under Section 120-A IPC. Citing Yogesh alias Sachin Jagdish Joshi v. State of Maharashtra (2008) and Bilal Hajar alias Abdul Hamid v. State (2019), the Court held that the meeting of minds of two or more persons for doing an illegal act or an act by illegal means is the "sine qua non" of criminal conspiracy, but that since conspiracies are always hatched in secrecy, their existence can be inferred from surrounding circumstances and the conduct of the accused.

"A conspiracy is always hatched in secrecy and is never an open affair to anyone much less the public at large."

On the Acquittal of Gurmeet Ram Rahim Singh

The centerpiece of the judgment is its analysis of the evidence against A1. The Court found it deeply significant that A1 was not named in the FIR, not named in the disclosure statements of A2 and A3, and not named in the CBI's initial investigation. He was named for the first time in 2007 — nearly five years after the incident — solely on the basis of the statement of Khatta Singh (PW31), who was alleged to be A1's driver.

The Court traced the turbulent career of Khatta Singh's evidence in painstaking detail. In December 2006, when Khatta Singh opened up for the first time, he spoke only about the conspiracy in the Ranjit Singh murder case — he did not implicate A1 in the present case. In March-April 2007, he filed multiple applications to the Magistrate, Sessions Court and the Superintendent of Police complaining that CBI was threatening and pressurizing him to falsely implicate A1. He appeared as PW31 during trial and turned hostile, deposing that CBI had coerced him. He was only re-examined after A1's conviction in the rape case in August 2017, when he claimed he had "mustered the courage" to tell the truth.

"He chose to remain silent for a number of years and then kept on tossing from one side to the other like a ping pong ball."

The Court declined to accept the explanation that Khatta Singh had previously remained silent out of fear from A1's Dera, particularly noting the internal inconsistency: if he was under such fear, it was inexplicable why he had named A1 in the Ranjit Singh murder case in 2006 without similar hesitation.

"This Court will not hesitate in holding that on the contrary, it appears that he was coerced by CBI into making a statement as CBI was under pressure to conclude the investigation."

The Court then pointed to additional corroborative failures. Khatta Singh's statement alleged that on October 23, 2002, he had accompanied A1 to Jalandhar for a Satsang, and that it was there and then that A1 had directed the murder of Ram Chander Chhatrapati. The Court noted that the Pura Sach edition of October 27, 2002 itself reported that the Satsang had been at Zira — approximately 150 kilometres from Jalandhar — not at Jalandhar at all. The head of the CBI investigation admitted in cross-examination that A1's visit to Jalandhar and the holding of a Satsang there had never been verified by the CBI during investigation.

"The prosecution was not able to prove its case against A1 beyond reasonable doubt."

The Court also placed great weight on the non-examination of SI Ram Chander, the police officer who had recorded the statement of Ram Chander Chhatrapati in PGI, Rohtak on October 26, 2002 — while the victim was alive and conscious. This statement was never brought on record. The prosecution gave him up as "unnecessary." The Court called this inexplicable, noting that the victim's condition records showed he was "conscious and oriented" from October 26 right up to November 1, 2002. The Court observed that since the sole charge against A1 was criminal conspiracy, this statement would have been of "extreme importance on either side." Its suppression created a reasonable doubt that had to enure to the benefit of A1.

Applying the celebrated principles in Sharad Birdhichand Sarda v. State of Maharashtra (1984) on circumstantial evidence, the Court held that where two possibilities — one of commission and one of innocence — are reasonably possible, the accused is entitled to the benefit of doubt. The Court also observed, in a pointed remark, that the "greater possibility" on the evidence was that A2, A3 and A4 had acted on their own accord as fanatical followers of the Dera, without the direction of A1.

"Courts and Judges should not be swayed by media reports and the public attention which a matter receives. Matters are required to be decided strictly as per law."

The Punjab and Haryana High Court dismissed the appeals of Kuldeep Singh alias Kala, Nirmal Singh, and the legal representatives of Krishan Lal alias Kishan Lal, upholding their conviction and sentence of life imprisonment under Sections 302 and 120-B IPC. The appeal of Gurmeet Ram Rahim Singh was allowed, his conviction and sentence were set aside, and he was acquitted of the charge of criminal conspiracy. The Court found the sole eyewitness to the alleged conspiracy — Khatta Singh — wholly unreliable, the CBI's methodology in obtaining his statement deeply concerning, and the non-production of the dying statement of the victim's own statement a fatal lacuna that created a reasonable doubt in favour of A1.

Date of Decision: March 7, 2026