MEMORIAL ON BEHALF OF THE

RESPONDENT-APPELLANTS

TEAM CODE - RCL-03

BEFORE THE HON'BLE HIGH COURT OF UTTARAKHAND

(CRIMINAL APPELLATE JURISDICTION)

CRIMINAL APPEAL NO. _____ OF 2024
IN THE MATTER OF:
BABLU ARYA & ORS.
(RESPONDENT-APPELLANTS)
V.
THE STATE & ANKITA BHANDARI'S PARENTS
(PETITIONERS)

WRITTEN SUBMISSION ON BEHALF OF THE

RESPONDENT-APPELLANTS

I. LIST OF ABBREVIATIONS

Abbreviations Meaning
& and
Anr. Another
Art. Article
BNS Bharatiya Nyaya Sanhita, 2023
Cr.L.J. Criminal Law Journal
HC High Court
Hon'ble Honorable
i.e. that is
Ors. Others
R.I. Rigorous Imprisonment
SC Supreme Court
SCC Supreme Court Cases
Sec. Section
S.L.P. (Crl.) Special Leave Petition (Criminal)
u/s Under Section
v. versus

II. INDEX OF AUTHORITIES

A. Case Laws

1. Anvar P.V. v. P.K. Basheer, (2014) 10 SCC 473

2. Bachan Singh v. State of Punjab, AIR 1980 SC 898
3. Bengal Chemicals Ltd. v. Their Workmen, AIR 1959 SC 633 1
4. Bhola v. State, 1974 Cri.L.J. 1318 (All.) 1
5. Chandra Singh v. State of Rajasthan, AIR 2003 SC 2889 1
6. Dhananjoy Cha�erjee @ Dhanna v. State of West Bengal, (1994) 2 SCC 220 1
7. Dinanath Singh v. State of Bihar, AIR 1980 SC 1199 1
8. George G. Feller v. The King, AIR 1943 PC 211 1
9. Gopal Singh v. State of U�rakhand, (2013) 7 SCC 545 1
10. Gurcharan Singh v. State (Delhi Admn.), (1978) 1 SCC 118 1
11. Jamshed Hormusji Wadia v. Board of Trustees, Port of Mumbai, AIR 2004 SC 1815 1
12. J.P. Builders v. A. Ramadas Rao, (2011) 1 SCC 429 1
13. Macchi Singh v. State of Punjab, 1983 AIR 957 2
14. Mahesh Balmiki alias Munna v. State of Madhya Pradesh, (2000) 1 SCC 319 1
15. Mahesh v. State of Madhya Pradesh, (1987) 2 SCR 710 1
16. Manoj v. State of M.P., Criminal Appeal No. 285 of 2022 4
17. Mathai @ Joby v. George, (2010) 4 SCC 358 1
18. Municipal Board, Pratabgarh v. Mahendra Singh Chowla, (1982) 3 SCC 331 1
19. Narinder Singh v. State of Punjab, (2014) 6 SCC 466 1
20. Narpat Singh v. Jaipur Development Authority, (2002) 3 SCR 365 1
21. Palvinder Kaur v. State of Punjab, AIR 1952 SC 354 5
22. Pritam Singh v. The State, AIR 1950 SC 169 1
 23. Ramji Prasad v. Ra�an Kumar Jaiswal and Anr., 2002 (9) SCC 366 1
24. Ram Sanjiwn Singh v. State of Bihar, AIR 1996 SC 3265 1
25. Riel v. The Queen, (1885) 10 AC 675 1
26. Shail Kumari v. State of Chha�isgarh, 2025 INSC 936 6
27. Shailesh Jasvantbhai and Anr. v. State of Gujarat and Ors, (2006) 2 SCC 359 1
28. Sharad Birdhichand Sarda v. State of Maharashtra, AIR 1984 SC 1622 6
29. Shyam Narain v. The State of NCT of Delhi, AIR 2013 SC 2209 1
30. State of Maharashtra v. Anand Chintaman Dighe, (1990) 1 SCC 397 1
31. State of Maharashtra v. Mayer Hans George, AIR 1965 SC 722 1
32. State of U.P. v. Deoman Upadhyaya, AIR 1960 SC 1125 7
33. Surendra v. State, 1977 Cr.L.J. 351 1
34. Tirupati Balaji Developers Pvt. Ltd. v. State of Bihar, AIR 2004 SC 2351 1
35. U.J.S. Chopra v. State of Bombay, AIR 1955 SC 633 1
36. Vaibhav v. State of Maharashtra, Criminal Appeal No. 226 of 2020 8
37. Vinay Kumar v. Narendra and Ors., 2002 (9) SCC 364 1

B. Statutes/Bare Acts

1. The Bharatiya Nyaya Sanhita, 2023 1

2. The Indian Evidence Act, 1872
3. The Code of Criminal Procedure, 1973

C. Books/Commentaries

1. Constitutional Law of India, Dr. Narender Kumar - 9th Edition, 2016

2. The Code of Criminal Procedure, 1973, S.N. Mishra-20th Edition, 2016
3. R.V. Kelkar's Criminal Procedure-6th Edition, reprint 2015
4. Indian Penal Code, Prof. S.N. Mishra-20th Edition, 2016

D. Legal Databases and Other Internet Sources

1. www.scconline.com
2. www.manupatra.com
3. www.livelaw.in
4. www.indiankannon.org
5. www.legalindia.com
6. www.prsindia.org
7. www.mha.gov.in
 8. www.scobserver.in
9. www.testbook.com

III. STATEMENT OF JURISDICTION

The Hon'ble High Court of U�arakhand has the requisite jurisdiction to hear the present
appeal from the judgment of the fast track trial court. The Respondent-Appellants have
approached this Hon'ble Court seeking acqui�al from the charges and se�ing aside of the
conviction under Sections 103, 63, and 61 of the Bharatiya Nyaya Sanhita, 2023. The present
appeal is maintainable under the criminal appellate jurisdiction of this Hon'ble Court.

IV. STATEMENT OF FACTS

Ankita Bhandari, a 19-year-old, commenced her employment as a receptionist at Vanantra

Resort in Yamkeshwar in August 2024. Less than a month later, her life tragically ended.
According to the prosecution's narrative, on the night of August 18, 2024, a confrontation
ensued between Ankita and her employer, Bablu Arya, along with resort sta� members Ankur
Gupta and Saurabh Bhaskar. The prosecution further alleges that Ankita was then forcibly
pushed into the Cheela canal and drowned.1 The prosecution's case is built upon
circumstantial pillars, including a "last seen" theory, a supposed motive related to "special
services," and certain electronic records and disclosure statements.1 A post-mortem at AIIMS
Rishikesh con�rmed drowning as the cause of death but noted that the injuries could be
consistent with an accidental fall and found a negative DNA report regarding the chance of
rape.1
The defence, in its counter-narrative, vehemently contests the prosecution's version, asserting
it is fraught with inconsistencies and procedural irregularities.1 The accused have maintained
that Ankita was emotionally disturbed due to a personal ma�er and may have commi�ed
suicide or fallen into the canal by accident.1 The defence has consistently highlighted that the
recovery of the body was made days a�er the incident, raising substantial doubts about the
chain of custody and the cause of death.1 Furthermore, any alleged "confessions" made by
the accused during police interrogation were not voluntary and are legally inadmissible. 1 The
defence also disputes the credibility of witness statements and the reliance on electronic
records, arguing they constitute inadmissible hearsay and lack the requisite legal
authentication.1
A series of external events created a highly prejudicial environment, severely compromising
the accused's right to a fair trial. The case's initial handling by a "patwari" (revenue o�cer)
system caused a critical delay in registering a criminal case.1 Public anger, fueled by intense
media coverage, led to the vandalization of the resort and an a�ack on a police vehicle
transporting the accused.1 The state's act of bulldozing the resort, citing illegal construction,
created a powerful and harmful presumption of guilt before the trial even began, e�ectively
denying the accused a fair defence.1
Based on circumstantial evidence, the trial court convicted the accused under Section 103
(murder), Section 63 (rape), and Section 61 (criminal conspiracy) of the Bharatiya Nyaya
Sanhita, 2023, and awarded life imprisonment.1 The deceased's parents have since appealed
for the death penalty, while the accused have appealed for acqui�al before this Hon'ble
Court.1
The following is a chronological summary of the key events:

Table of Dates and Events

Date Event
August 2024 Ankita Bhandari begins working at Vanantra
Resort. 1
August 18, 2024 Alleged confrontation and disappearance of
Ankita Bhandari. 1
August 18, 2024 (Post-Incident) Alleged �ling of missing person report by the
accused. 1
August 18-24, 2024 Delay in registering a criminal case due to
jurisdiction falling under a "patwari." 1
August 24, 2024 Body recovered from the Cheela canal based
on disclosure statements. 1
Post-August 24, 2024 Public outrage, media trial, and bulldozing of
Vanantra Resort. 1
Fast track trial court convicts the accused
under BNS Sections 103, 63, and 61. 1
Both the deceased's parents and the accused
�le appeals before the High Court. 1

V. STATEMENT OF ISSUES RAISED

1. Whether the accused had the requisite mens rea to cause death and commit the other
charged o�ences?
2. Whether the prosecution proved guilt beyond reasonable doubt in light of evidentiary
contradictions and procedural lapses?
3. Whether the case quali�es as a "rarest of rare" case warranting the death penalty?
VI. SUMMARY OF PLEADINGS

It is humbly submi�ed before this Hon'ble Court that the conviction of the
Respondent-Appellants is legally and factually unsustainable. The prosecution’s case is built
entirely on circumstantial evidence that fails to form a complete and unbroken chain, as is the
mandatory requirement under Indian law. The prosecution has failed to establish the
fundamental element of mens rea, as the evidence does not rule out the plausible alternative
hypothesis of suicide or accidental death. The case lacks the "conclusive" nature of evidence
required for a conviction on circumstantial grounds.
Furthermore, the key pieces of evidence relied upon by the prosecution are legally
inadmissible and carry no probative value. The "last seen" theory is fatally undermined by the
signi�cant six-day time gap between the alleged sighting and the recovery of the body. The
purported confessions are inadmissible under the Indian Evidence Act, as the police already
had prior knowledge of the body's location, nullifying the limited exception for discovery
statements. The electronic records, crucial to the prosecution's motive theory, lack the
mandatory legal authentication, rendering them legally worthless. Finally, the witness
testimony related to the motive is unsubstantiated hearsay and cannot be relied upon.
The trial itself was fundamentally unfair, having been severely prejudiced by unexplainable
procedural delays and an overwhelming public and media trial. The state's actions, including
the symbolic bulldozing of the resort, created a public perception of guilt that directly
interfered with the accused's constitutional right to a fair trial.
Given the absence of direct evidence, the legal and evidentiary �aws in the prosecution's
case, the presence of a strong alternative hypothesis, and the substantial mitigating factors,
the case in no way quali�es for the "rarest of rare" doctrine. The sentence of life
imprisonment, let alone the death penalty sought by the Petitioners, is wholly unjust. The
cumulative e�ect of these failures necessitates the acqui�al of the Respondent-Appellants.

VII. PLEADINGS SUBMITTED

1. ON THE LACK OF REQUISITE MENS REA AND THE FAILURE TO PROVE GUILT
BEYOND REASONABLE DOUBT.

The prosecution’s case against the Respondent-Appellants rests entirely on circumstantial

evidence, a framework that requires a higher standard of proof than direct evidence. A person
can be convicted on the basis of circumstantial evidence alone, but the evidence must be of a
very high standard, as the prosecution must establish a complete chain of circumstances that
leads to the "inescapable" conclusion of the accused's guilt, leaving no room for any other
logical hypothesis.14 The Hon'ble Supreme Court, in the landmark case of
Sharad Birdhichand Sarda v. State of Maharashtra, laid down �ve foundational principles that
must be satis�ed for a conviction to be sustained on circumstantial evidence. These principles
are:
1. The circumstances from which the conclusion of guilt is to be drawn must be fully
established.
2. The facts so established should be consistent only with the hypothesis of the guilt of
the accused.
3. The circumstances should be of a conclusive nature and tendency.
4. They should, to all human probability, exclude every hypothesis except the one
proposing the guilt of the accused.
5. There must be a chain of evidence so complete as not to leave any reasonable ground
for a conclusion consistent with the innocence of the accused and it must be such as to
show that within all human probability the act must have been done by the accused.6
The prosecution’s narrative in the present case fails to meet these stringent requirements. The
evidence presented, when viewed critically, is riddled with contradictions and is explainable on
hypotheses other than the guilt of the accused. The fundamental premise of the case, the
presence of the requisite mens rea—the guilty mind or intention to kill—is le� unproven and
speculative. Mens rea is an essential element for a conviction under Section 103 BNS
(murder), and it must be a clear intention to kill or knowledge that the act will likely cause
death.9 The prosecution's case is a house of cards, where each pillar of evidence is �imsy and
collapses under legal scrutiny.

A. The Unreliability and Inadmissibility of Prosecution Evidence.

The prosecution's case is constructed upon several pillars of evidence, each of which is
demonstrably weak, legally inadmissible, or both.

i. The Frailty of the 'Last Seen' Theory

The theory that the deceased was last seen in the company of the accused is a form of
circumstantial evidence and is considered a weak basis for conviction, particularly when it
stands alone. Precedents have consistently held that a conviction cannot be sustained solely
on this theory unless the time gap between the sighting and the recovery of the body is
extremely short, ruling out the possibility of any other person intervening.16 The time span
must be so short that it removes the possibility of another individual commi�ing the crime. 18
In the present case, the time elapsed between the alleged last sighting on August 18 and the
recovery of the body on August 24 is a substantial period of six days.1 This signi�cant time gap
is a fatal �aw. It creates a vacuum of information and allows for the intervention of a multitude
of other possibilities, including the intervention of a third party, an accidental fall, or
self-harm, which cannot be ruled out.1 The absence of a continuous, unbroken chain of events
during this critical period means that the "last seen" evidence cannot be used to establish
guilt. The passage of time not only diminishes the evidentiary value of the sighting but also
fundamentally erodes the causal link the prosecution seeks to establish between the
accused's presence and the victim's death. The prosecution cannot logically assert that the
accused had the intention to cause death when the circumstances of death remain unknown
for such a long period. The integrity of this key piece of circumstantial evidence is completely
compromised, and it is insu�cient to form the basis of a conviction, especially for a serious
charge like murder.
The legal principle, as a�rmed in recent judgments like Shail Kumari v. State of Chha�isgarh,
is that the prosecution must establish a complete and reliable chain of events beyond a
reasonable doubt, and the 'last seen' theory alone is insu�cient to do so, particularly when
there is a signi�cant time gap.6 The burden of proof is not on the accused to explain the
circumstances of death; rather, it is on the prosecution to prove guilt beyond a reasonable
doubt, a burden they have failed to meet by relying on such a weak theory.18 The mere fact
that the accused were last seen with the deceased is not enough to sustain a conviction for
murder; there must be a complete chain of circumstances that excludes any other hypothesis
besides the accused's guilt.16

ii. The Inadmissibility of Confessions and Disclosure Statements

The prosecution's reliance on a disclosure statement by the accused, which allegedly led to
the recovery of the body, is a legal manoeuvre that fails under scrutiny. Indian law, speci�cally
Section 25 of the Indian Evidence Act, 1872, strictly prohibits the admission of a confession
made to a police o�cer.7 This rule is a fundamental safeguard against coerced confessions
and custodial violence, and it is unique to India's legal framework.7 This provision was
speci�cally inserted to address the malpractice of using torture to extort confessions from
suspects.19
While Section 27 of the Act provides a limited exception, allowing for the admission of
information that leads to a "discovery of fact," this exception is not applicable here. 20 The
moot proposition explicitly states that "One sta� member pointed out to police about this
fact," referring to the body being pushed into the Cheela canal.1 This fact demonstrates that
the police were already aware of the body's likely location. The subsequent recovery was
therefore not a unique discovery stemming from the accused's statement, but rather a
pre-existing fact in the knowledge of the police. For a statement to be admissible under
Section 27, the discovery must be the direct and immediate consequence of the accused's
information, and the information given by the accused must connect directly to the fact
discovered.5 Because the police possessed prior knowledge of the location, the accused’s
statement cannot be legally said to have “led to the discovery.”21 This failure to meet the strict
conditions of the exception renders the confession and any accompanying discovery
statement legally void and inadmissible.
Furthermore, a confession must be taken as a whole. The Hon'ble Supreme Court, in Palvinder
Kaur v. State of Punjab, held that a confession that contains both self-incriminating and
exculpatory (self-clearing) statements cannot be used selectively by the prosecution.22 The
prosecution cannot use a self-incriminating part while conveniently ignoring the exculpatory
parts of the same statement.5 In the present case, the accused's statements, if they indeed
led to the recovery, must be seen in conjunction with their defence that Ankita was
emotionally disturbed and may have commi�ed suicide or fallen by accident.1 The prosecution
cannot cherry-pick the self-incriminating parts while discarding the rest.

iii. The Failure to Authenticate Electronic Records

The prosecution has placed an undue reliance on alleged audio recordings between the
accused and Pulkit, the deceased's friend. However, such electronic records are not
automatically admissible in a court of law. As per the binding precedent set by the Hon'ble
Supreme Court in Anvar P.V. v. P.K. Basheer, any electronic record submi�ed as secondary
evidence must be accompanied by a mandatory certi�cate under Section 65B of the Indian
Evidence Act.24 This certi�cate must identify the electronic record, describe the manner in
which it was produced, and certify that the device used was operating properly during the
relevant period.13
The prosecution’s case is silent on the existence of such a certi�cate, which is a signi�cant
legal omission. The failure to comply with this non-negotiable legal requirement means the
entire piece of electronic evidence is rendered legally worthless. The recordings cannot be
considered a document in the eyes of the law without this certi�cate.13 This technical yet
critical point of law means the prosecution's claim regarding the misleading nature of the
accused's statements is legally unproven. Without the Section 65B certi�cate, the electronic
evidence, which is the very foundation of the prosecution's motive theory, is inadmissible and
cannot be relied upon for a conviction.

iv. The Hearsay Nature of Pulkit’s Testimony

The prosecution's entire case for motive—that the accused were pressuring the deceased to
provide "special services"—rests solely on the testimony of Pulkit, who claims Ankita told him
about this pressure.1 This statement is a classic example of hearsay evidence, de�ned as a
statement made by a person not called as a witness, and therefore, not subject to
cross-examination.27 The very nature of hearsay is that it is unreliable, as the original speaker
is not present to be cross-examined on their statement.27
Hearsay is generally inadmissible in court as it is considered unreliable and uncorroborated. 28
The statement does not fall under any of the recognized exceptions to the hearsay rule, such
as a dying declaration or
res gestae.29 A dying declaration is a statement made by a person who is about to die
concerning the cause of their death, based on the principle that a person nearing death is
unlikely to lie.29 The prosecution's case does not present this as a dying declaration, and the
deceased was not speaking in expectation of death when she allegedly made the statement
to Pulkit.1 Similarly, the statement does not fall under the doctrine of
res gestae, which requires the u�erance to be so closely connected to the act as to form part
of the same transaction, made under the pressure of the moment.31 Pulkit's statement is about
a prior conversation, not a contemporaneous reaction to the alleged crime, and therefore
does not form part of the same transaction.
The unproven and unsubstantiated nature of this motive severely weakens the prosecution's
case. The burden to prove a motive and a guilty intention (mens rea) for murder falls squarely
on the prosecution. When the only evidence for motive is based on a legally inadmissible
statement, the very foundation of the prosecution's case for murder collapses.

B. The Plausible Alternative Hypothesis of Suicide or Accidental Fall.

The defence has consistently presented an alternative, and equally plausible, hypothesis that
the deceased was emotionally disturbed and may have commi�ed suicide or fallen into the
canal by accident.1 The prosecution has failed to conclusively rule out this possibility. The
post-mortem report itself notes that the injuries sustained by the deceased "could also be
consistent with accidental slipping into the canal," thereby supporting the defence's
hypothesis.1 Furthermore, the post-mortem report's �nding of a "negative DNA Report on
chance of rape" completely undermines the charge under Section 63 BNS and reinforces the
defence’s position that the alleged assault did not occur.1
The law is well-se�led that where two views of the facts exist, one favoring the prosecution
and the other the defence, the one favoring the accused must be taken. As the Hon'ble
Supreme Court noted in Vaibhav v. State of Maharashtra, in cases based on circumstantial
evidence, the court must compare the prosecution's evidence with that of the defence, and a
�nding of conviction must be made out beyond a reasonable doubt.8 The prosecution has
failed to discharge this burden. The existence of this alternative hypothesis, supported by the
medical evidence, is su�cient to create reasonable doubt and necessitates acqui�al.

2. ON THE INAPPLICABILITY OF THE ‘RAREST OF RARE’ DOCTRINE.

Even if, arguendo, the conviction were to be upheld, the imposition of the death penalty would
be legally untenable. The death penalty is not a default punishment but an exceptional one,
reserved for the "rarest of rare" cases as established by the Hon'ble Supreme Court in the
landmark judgment of Bachan Singh v. State of Punjab.33 The Court further clari�ed the
guiding principles for this doctrine in
Macchi Singh v. State of Punjab, outlining �ve categories of cases that may warrant capital
punishment, including the manner of commission, motive, and the socially heinous nature of
the crime.37
A. The Case Lacks the Heinous Aggravating Factors for a Death Sentence.

The facts of the present case, as presented by the prosecution and contested by the defence,
do not meet the high threshold for a death sentence. The alleged murder was not commi�ed
in an "extremely brutal, heinous, and diabolical" manner that would shock society's
conscience, as required by the law.38 The unproven and unsubstantiated motive of "special
services" does not constitute a "total depravity and cruelty" that would justify the death
penalty.38 Unlike cases of mass murder, terrorism, or the killing of a public servant, this case
does not have the kind of "anti-social nature" or "magnitude of the crime" that would place it
in the rarest of rare category.2 The alleged act, as per the prosecution's own narrative, was a
single, forcible drowning—not a prolonged, torturous, or gruesome act that would qualify as
"inhuman" in the sense required for capital punishment.

B. The Presence of Signi�cant Mitigating Factors.

The law requires a meticulous "balance sheet" of aggravating and mitigating factors to be
prepared and considered before awarding the death penalty.38 The mitigating circumstances
in this case are compelling and far outweigh any alleged aggravating factors.
1. Circumstantial Nature of the Case: The prosecution's case is based on circumstantial
evidence, which, as has been argued, is fundamentally �awed. In the absence of a
direct, conclusive link between the accused and the victim's death, awarding capital
punishment would be disproportionate and unjust.
2. Unproven Motive: The prosecution has failed to establish a corroborated motive. The
entire argument for the accused's intention is based on inadmissible hearsay evidence.
The absence of a proven, malicious motive is a signi�cant mitigating factor.
3. Procedural Lapses and External Prejudice: The accused were denied a fair trial due
to multiple factors. The delay in the registration of the criminal case caused by the
"patwari" system, followed by the intense media trial and the state-sanctioned
bulldozing of the resort, created an environment of extreme prejudice.1 The Supreme
Court has recognized that "trial by media" can lead to a public perception of guilt that
directly impinges upon an accused person's right to a fair defence and the presumption
of innocence under Article 21 of the Constitution.39 As noted in the case of
R.K. Anand v. Delhi High Court, media can create "an atmosphere of public hysteria akin
to a lynch mob" which makes a fair trial nearly impossible.12 The accused's fundamental
right to a fair trial was demonstrably compromised by these external forces. The state's
action of bulldozing the resort created a powerful and damaging presumption of guilt
even before the trial began, a form of public punishment without judicial sanction.1 This
prejudicial atmosphere that permeated the investigation and trial is a profound
mitigating circumstance that must be considered. In recent judgments, such as
Manoj v. State of M.P., the Supreme Court has emphasized that courts must take into
 account the social background and psychological factors of a convict and not rely solely
on the brutality of the crime when a�rming the death penalty.4 The conviction, and
consequently the sentence, were reached in a context where justice was not only
delayed but also compromised by external pressures.

VIII. PRAYER

WHEREFORE, in light of the issues raised, arguments advanced, and authorities cited, it is
most humbly and respec�ully prayed before this Hon'ble High Court:
1. To set aside the judgment of conviction and sentence passed by the trial court.
2. To acquit the Respondent-Appellants of all charges levelled against them.
AND/OR
3. In the alternative, to commute the sentence of life imprisonment to a term that is just
and equitable, considering the circumstantial nature of the evidence and the mitigating
factors.
For which act of kindness, the Respondent-Appellants shall forever pray.
Respec�ully Submi�ed,
Counsel for the Respondent-Appellants
Team Code: RCL-03

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