Can the lack of independent corroboration of an approver’s testimony overturn a murder conviction based on poisoned sweets in the Punjab and Haryana High Court?

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Suppose a person is charged under the Indian Penal Code for the murder of a relative’s spouse after allegedly mixing a toxic substance into a traditional sweet and delivering it through a hired intermediary, and the prosecution’s case rests primarily on the testimony of that intermediary who has turned approver.

The investigating agency files an FIR describing the alleged poisoning, the procurement of the toxic material, and the delivery of the sweets to the victim’s household. The accused is taken into custody, and the trial court records the approver’s statement, which details the accused’s role in obtaining the poison, preparing the confectionery, and handing it over to the intermediary. The trial court, after evaluating the evidence, convicts the accused and imposes a term of rigorous imprisonment.

On appeal, the accused contends that the approver’s testimony is unreliable because it lacks independent corroboration on the material points that link the accused directly to the preparation of the poisoned sweets. The defence argues that the prosecution has not produced any documentary proof of the purchase of the toxic substance by the accused, nor any eyewitness identification of the accused at the scene of the alleged preparation, and therefore the conviction is unsafe.

While the accused’s ordinary factual defence—denying participation in the alleged act—addresses the substantive allegations, it does not remedy the procedural defect that the trial court may have erred in admitting uncorroborated approver evidence. Under established jurisprudence, an approver’s testimony must be supported by independent evidence on material aspects of the charge; otherwise, the conviction may be set aside on the ground of insufficient corroboration.

Because the conviction has already been pronounced by the Sessions Court, the appropriate procedural route to challenge the admissibility of the approver’s evidence and the resultant judgment is a criminal appeal before the Punjab and Haryana High Court. The appeal under the provisions governing appeals against conviction allows the higher court to scrutinise whether the lower court correctly applied the two‑fold test of reliability and material corroboration for approver testimony.

A lawyer in Punjab and Haryana High Court would draft the appeal, specifically raising the issue that the trial court failed to apply the test articulated in precedent, and would seek a reversal of the conviction or, at the very least, a remand for fresh evidence. The appeal would cite the lack of a purchase register, the absence of any independent witness to the accused’s alleged handling of the poison, and the reliance on a single approver whose statements are not independently verified.

In addition, the accused may also consider filing a revision petition under the Criminal Procedure Code, arguing that the Sessions Court committed a jurisdictional error by not requiring the mandatory corroboration of the approver’s testimony. Such a revision would be entertained by the Punjab and Haryana High Court, which possesses the authority to examine whether the lower court’s findings were perverse or legally untenable.

Lawyers in Chandigarh High Court often advise that, when the primary ground of appeal is the admissibility of approver evidence, the appellant must meticulously demonstrate the specific material points that lack corroboration. The petition would therefore attach the FIR, the trial court’s judgment, and the transcript of the approver’s testimony, highlighting the gaps in the prosecution’s case.

The procedural advantage of approaching the Punjab and Haryana High Court lies in its power to set aside the conviction, order a retrial, or direct the investigating agency to re‑examine the evidence. The High Court can also grant bail pending the determination of the appeal, thereby addressing the immediate custodial hardship faced by the accused.

A lawyer in Chandigarh High Court would further argue that the accused’s right to a fair trial under the Constitution is compromised when the prosecution relies on uncorroborated approver testimony. The appeal would invoke the principle that the burden of proof rests on the State, and that any doubt as to the reliability of the approver must be resolved in favour of the accused.

Thus, the legal problem—whether the conviction can stand on the basis of a solitary approver’s uncorroborated testimony—finds its remedy in filing a criminal appeal (and, if necessary, a revision) before the Punjab and Haryana High Court. The High Court’s jurisdiction to entertain such appeals ensures that the procedural safeguards enshrined in criminal law are observed.

Lawyers in Punjab and Haryana High Court would prepare the appeal with precise citations to case law on approver evidence, emphasizing that the trial court’s acceptance of the testimony without the requisite corroboration constitutes a reversible error. The relief sought would be the quashing of the conviction and the issuance of a direction for the prosecution to either produce fresh, corroborated evidence or dismiss the charges.

In summary, the fictional scenario mirrors the core legal issue of the analysed judgment: the necessity of corroborating an approver’s testimony on material points before a conviction can be sustained. By filing the appropriate appeal before the Punjab and Haryana High Court, the accused avails himself of the procedural mechanism designed to correct such legal missteps, thereby safeguarding the integrity of the criminal justice process.

Question: How does the requirement of independent corroboration affect the admissibility of the approver’s testimony in the present murder prosecution?

Answer: The factual matrix shows that the prosecution’s case hinges on the statements of a single approver who alleged that the accused procured a toxic substance, mixed it into a traditional sweet and handed it to an intermediary for delivery. Under established criminal jurisprudence, an approver’s testimony is admissible only if it satisfies two limbs: the witness must be deemed reliable and the core material points of the testimony must be corroborated by independent evidence. In this scenario, the material points include the accused’s procurement of the poison, the preparation of the poisoned confectionery, and the hand‑over to the intermediary. The trial court admitted the approver’s narrative without any documentary proof of purchase, no eyewitness identification of the accused at the site of preparation, and no forensic linkage of the poison to the accused’s hands. Consequently, the lack of corroboration raises a serious procedural defect. A lawyer in Punjab and Haryana High Court would argue that the trial court’s failure to apply the two‑fold test renders the conviction unsafe, because the State bears the burden of proving each material element beyond reasonable doubt. The High Court, when reviewing the appeal, will scrutinise whether the prosecution produced any independent evidence—such as purchase registers, receipts, or testimony from third parties—that confirms the accused’s direct involvement. If the court finds that the only evidence of the accused’s participation is the uncorroborated approver’s account, it must conclude that the evidentiary threshold has not been met, leading to a possible quashing of the conviction or a remand for fresh evidence. The legal significance, therefore, lies in safeguarding the accused’s constitutional right to a fair trial by ensuring that a conviction is not predicated solely on a single, unverified narrative, and the appellate forum is empowered to correct such an error. The outcome will directly influence whether the conviction stands or is set aside, underscoring the pivotal role of corroboration in criminal trials.

Question: In what manner will the appellate court evaluate the reliability of the approver’s statements when there is an absence of independent corroboration?

Answer: The appellate court’s assessment of reliability proceeds on a factual and contextual basis. It will first examine the circumstances under which the approver turned state‑witness, including any inducements, promises of leniency, or threats that might impinge upon his credibility. The court will also consider the internal consistency of the approver’s narrative, looking for contradictions, omissions, or implausible details. In the present case, the approver’s testimony is the sole conduit linking the accused to the procurement and preparation of the poison. Lawyers in Chandigarh High Court would emphasize that reliability cannot be inferred merely from the absence of contradictions; it must be anchored in external verification. The appellate bench will therefore evaluate whether any circumstantial evidence—such as the presence of the toxic substance at the accused’s residence, forensic traces on the sweets, or communications between the accused and the intermediary—supports the approver’s version. If the prosecution’s case lacks such corroboration, the court may deem the approver’s testimony insufficiently reliable, especially given the gravity of a murder charge. Moreover, the court will weigh the approver’s motive to shift blame and secure a reduced sentence, which can erode trustworthiness. The legal standard requires that any doubt as to reliability be resolved in favour of the accused, reflecting the principle that the burden of proof lies with the State. Consequently, the appellate court may either set aside the conviction on the ground of unreliable, uncorroborated testimony or remand the matter for further investigation to obtain corroborative material. This evaluation directly impacts the accused’s right to be judged on a solid evidentiary foundation and ensures that the conviction is not predicated on a potentially self‑serving statement. The court’s decision will also guide future prosecutions on the necessity of securing independent corroboration before relying on approver evidence.

Question: What procedural avenues are available to the accused for challenging the conviction on the ground that the approver’s evidence was admitted without the requisite corroboration?

Answer: The accused can pursue several procedural remedies to contest the conviction. The primary route is to file a criminal appeal before the Punjab and Haryana High Court, invoking the appellate jurisdiction to examine whether the trial court erred in admitting the approver’s testimony without the mandatory corroboration on material points. A lawyer in Chandigarh High Court would draft the appeal, articulating that the conviction rests on a single uncorroborated narrative, thereby violating the established two‑fold test for approver evidence. The appeal must be supported by the FIR, the trial judgment, and the transcript of the approver’s statement, highlighting the gaps in the prosecution’s case. If the appellate court finds merit, it may set aside the conviction, order a retrial, or direct the investigating agency to procure additional evidence. In parallel, the accused may file a revision petition under the criminal procedural law, contending that the Sessions Court committed a jurisdictional error by not insisting on corroboration, a matter that can be entertained by the High Court even after the appeal is pending. Additionally, the accused can move for a writ of certiorari if there is a claim that the lower court acted ultra vires or perverse in its findings, though this is less common in criminal matters. The High Court also possesses the power to grant bail pending the determination of the appeal, thereby alleviating custodial hardship. Each of these procedural avenues serves to ensure that the conviction is scrutinised for compliance with constitutional safeguards and evidentiary standards, and they provide the accused with multiple layers of judicial review to rectify potential miscarriages of justice.

Question: How does the pending appeal before the Punjab and Haryana High Court affect the accused’s custodial status and what are the practical implications for bail?

Answer: While the appeal is pending, the accused remains in custody unless the High Court grants bail. The procedural framework allows the court to consider bail applications even after conviction, particularly when the appeal raises substantial questions about the evidentiary foundation of the judgment. Lawyers in Punjab and Haryana High Court would argue that the reliance on an uncorroborated approver’s testimony creates a reasonable doubt regarding the safety of the conviction, thereby satisfying the criteria for bail: the existence of a plausible ground for appeal, the absence of a risk of tampering with evidence, and the assurance that the accused will appear for further proceedings. The practical implication of granting bail is twofold: it relieves the accused of the immediate hardship of incarceration and enables him to actively participate in the preparation of his appeal, including gathering fresh evidence or securing expert testimony to challenge the prosecution’s case. Conversely, if bail is denied, the accused continues to serve the sentence, which may exert psychological pressure and limit his ability to effectively assist his counsel. The High Court’s discretion in bail matters also serves as a safeguard against potential miscarriage of justice, ensuring that the accused is not unduly punished while substantive legal issues are being resolved. Moreover, a bail order can set a precedent for similar cases where convictions rest on solitary approver evidence, reinforcing the principle that the State must meet the burden of proof before depriving an individual of liberty. The outcome of the bail application, therefore, has immediate consequences for the accused’s personal liberty and broader implications for the administration of criminal justice.

Question: Why does the procedural remedy for the conviction rest with the Punjab and Haryana High Court rather than any lower forum, and what jurisdictional principles make this the proper venue?

Answer: The factual matrix shows that the trial court, a Sessions Court, has already rendered a judgment of conviction and sentenced the accused to rigorous imprisonment. Under the hierarchy of criminal courts in India, any order of conviction passed by a Sessions Court is appealable to the High Court of the state in which the Sessions Court sits. The Punjab and Haryana High Court possesses the statutory authority to entertain criminal appeals against convictions, to examine the record for legal errors, and to exercise its supervisory jurisdiction over subordinate courts. Because the offence of murder, as alleged in the FIR, is a serious non‑bailable offence, the High Court’s appellate jurisdiction is exclusive for reviewing the trial court’s findings on the admissibility of approver testimony and the adequacy of corroboration. The High Court can also entertain a revision petition if the appellate route is exhausted or if there is a manifest error of law that does not require a full appeal. In the present scenario, the accused’s primary grievance is that the trial court admitted the approver’s statement without the mandatory corroboration on material points. This is a question of law and procedural propriety, which the Punjab and Haryana High Court is empowered to scrutinise. Moreover, the High Court can grant interim relief such as bail, stay the execution of the sentence, or even quash the conviction if it finds the evidentiary foundation unsound. The jurisdictional basis is therefore rooted in the appellate hierarchy, the nature of the conviction, and the High Court’s power to correct legal missteps that affect the fairness of the trial. Engaging a lawyer in Punjab and Haryana High Court ensures that the appeal is framed in compliance with the procedural rules, that the correct reliefs are sought, and that the High Court’s jurisdiction is fully invoked to address the procedural defect that the factual defence alone cannot remedy.

Question: Why might the accused look for a lawyer in Chandigarh High Court even though the appeal is to be filed in the Punjab and Haryana High Court, and what practical considerations drive this search?

Answer: The city of Chandigarh serves as the shared capital of Punjab and Haryana and houses the principal registry of the Punjab and Haryana High Court. Consequently, many practitioners who regularly appear before the High Court maintain chambers in Chandigarh, and they are commonly referred to as lawyers in Chandigarh High Court. An accused seeking representation will therefore naturally turn to the pool of lawyers who are familiar with the High Court’s procedural nuances, its bench composition, and the local bar culture. The practical advantages include immediate access to the court’s filing facilities, the ability to attend hearings without extensive travel, and the benefit of counsel who have established relationships with the registry staff and who understand the docketing system. Moreover, lawyers in Chandigarh High Court are often well‑versed in drafting appeals, revision petitions, and bail applications specific to the High Court’s rules, which differ in form and substance from those of lower courts. This expertise is crucial when the appeal hinges on technical points such as the requirement for corroboration of approver testimony, the standards for granting bail pending appeal, and the procedural steps for seeking a stay of execution. Additionally, the accused may prefer counsel who can provide strategic advice on whether to pursue a direct appeal, a simultaneous revision, or a combination of both, based on the High Court’s case law. The proximity of the lawyers to the High Court also facilitates prompt filing of documents, timely responses to notices, and effective representation during oral arguments. Thus, the search for a lawyer in Chandigarh High Court is driven by jurisdictional convenience, specialized knowledge of High Court practice, and the logistical benefits that enhance the efficacy of the procedural challenge against the conviction.

Question: How does filing an appeal, and possibly a revision petition, address the deficiency of uncorroborated approver testimony beyond the accused’s ordinary factual defence?

Answer: The accused’s factual defence—denying participation in the alleged poisoning—targets the substantive elements of the charge. However, the conviction rests heavily on the approver’s testimony, which, under established jurisprudence, must be supported by independent corroboration on material points. A mere denial does not compel the trial court to revisit the evidentiary foundation; it merely contests the narrative. By filing an appeal before the Punjab and Haryana High Court, the accused invokes a higher judicial review that can scrutinise whether the trial court correctly applied the legal test for approver evidence. The appellate court can examine the trial record, assess the reliability of the approver, and determine if the prosecution produced any independent proof—such as purchase registers, eyewitness identification, or forensic evidence—linking the accused to the preparation of the poisoned sweets. If the High Court finds that the material aspects, like the procurement of the toxic substance or the actual mixing of the poison, lack corroboration, it can set aside the conviction on the ground of insufficient evidence, a remedy unavailable through factual defence alone. Additionally, a revision petition offers a supplementary avenue to challenge jurisdictional or procedural errors, such as the trial court’s failure to require mandatory corroboration before admitting the approver’s statement. The revision can be entertained by the same High Court, allowing the accused to raise the issue even if the appeal is pending, thereby expediting relief. Both procedural tools shift the focus from the accused’s narrative to the prosecution’s evidentiary burden, compelling the High Court to evaluate whether the legal standards for admissibility were met. This procedural route is essential because it addresses the structural flaw in the trial—admission of uncorroborated testimony—rather than merely contesting the factual allegations, thereby offering a more robust avenue for overturning the conviction.

Question: What steps must be taken to obtain bail pending the appeal, and why does the existence of a factual defence not automatically secure release?

Answer: Securing bail pending the appeal involves a multi‑step procedural process that must be initiated in the Punjab and Haryana High Court. First, the accused, through counsel, must file an application for bail under the appropriate High Court rule, attaching the appeal memorandum, the FIR, the conviction order, and any supporting material that demonstrates the likelihood of success on the merits, such as the lack of corroboration of the approver’s testimony. The application must also set out the grounds for bail, including the presumption of innocence, the possibility of a miscarriage of justice, and the fact that the accused is not a flight risk. The High Court will then consider the bail application, weighing factors such as the seriousness of the offence, the nature of the evidence, and the risk to the public. The mere existence of a factual defence—denial of involvement—does not automatically satisfy the bail criteria because bail is a matter of discretion that hinges on the strength of the legal arguments, not solely on the accused’s assertions. The High Court requires a demonstration that the conviction may be unsafe, which is precisely the argument advanced in the appeal concerning the uncorroborated approver evidence. Moreover, the court will assess whether the accused has cooperated with the investigating agency, whether there are pending investigations, and whether the accused has any prior criminal record. If the bail application is denied, the counsel may file a revision petition challenging the denial, again before the Punjab and Haryana High Court, highlighting any procedural irregularities in the bail decision. Engaging a lawyer in Punjab and Haryana High Court is crucial to craft a persuasive bail application that aligns with the High Court’s procedural requirements and to navigate the nuanced assessment of bail in serious non‑bailable offences. Thus, bail is not a right conferred by factual defence alone; it is a discretionary relief that must be earned through a rigorous procedural showing of the appeal’s merit and the accused’s suitability for release.

Question: How does the Punjab and Haryana High Court’s power to quash a conviction or direct a retrial function in this context, and why is this remedy essential given the facts?

Answer: The High Court’s appellate jurisdiction empowers it to set aside a conviction if it finds that the trial court erred in law or that the evidence does not meet the required standard of proof. In the present case, the conviction is predicated on the approver’s testimony, which, according to established legal principles, must be corroborated on material points such as the procurement of the poison and the actual mixing of the toxic substance. If the High Court, after a careful review of the trial record, determines that the prosecution failed to produce any independent evidence linking the accused to these material acts, it can exercise its power to quash the conviction. This would result in the immediate release of the accused from custody and the erasure of the criminal record, subject to any further investigation. Alternatively, the High Court may find that while the conviction cannot be entirely set aside, the trial court’s error warrants a fresh trial. In such a scenario, the High Court can direct the Sessions Court to reconduct the trial, ensuring that the evidentiary standards for approver testimony are strictly applied, and that the prosecution is required to present corroborative material before a conviction can be sustained. This remedial power is essential because the factual defence alone—simply denying involvement—does not address the procedural defect of uncorroborated evidence, which is a cornerstone of a fair trial. By invoking the High Court’s authority, the accused can obtain a substantive correction of the legal error, rather than merely a procedural stay. Engaging lawyers in Punjab and Haryana High Court ensures that the appeal is framed to highlight the lack of corroboration, that appropriate reliefs such as quashing or retrial are sought, and that the High Court’s supervisory jurisdiction is fully utilised to safeguard the accused’s constitutional right to a fair trial.

Question: How does the reliance on a single approver’s testimony without independent corroboration expose the accused to the risk of an unsafe conviction and what strategic arguments can be raised to seek quashing of the judgment?

Answer: The factual matrix shows that the prosecution’s case hinges on the narrative of the intermediary who turned approver. The approver describes the accused’s alleged procurement of the toxic substance, preparation of the confectionery and delivery to the victim’s household. No forensic sample, purchase receipt, eyewitness identification or surveillance footage corroborates those material points. In the absence of such corroboration the conviction rests on a solitary, self‑serving statement that may be motivated by the benefit of reduced liability. A lawyer in Punjab and Haryana High Court would therefore frame the appeal around the well‑settled principle that an approver’s evidence must be supported by independent proof on each essential element of the charge. The strategic line of attack would highlight the gaps: the missing purchase register, the lack of any shopkeeper testimony linking the accused to the toxic material, and the absence of any person who saw the accused mixing the poison. By demonstrating that the trial court failed to apply the two‑fold test of reliability and corroboration, the counsel can argue that the conviction is unsafe and should be set aside. The appeal would request that the High Court either quash the conviction outright or remit the matter for a fresh trial where the State must produce admissible evidence. In addition, the counsel may invoke the constitutional guarantee of a fair trial, emphasizing that the burden of proof lies with the State and that any doubt must be resolved in favour of the accused. The practical implication for the accused is that a successful quashing would remove the criminal liability and restore liberty, while a remand for fresh evidence would give the defence an opportunity to challenge the prosecution’s case on a more balanced footing. Lawyers in Chandigarh High Court often advise that the appellate brief should meticulously catalogue each material point lacking corroboration and attach the relevant portions of the approver’s statement to illustrate the deficiency. This approach maximizes the chance that the High Court will find a procedural infirmity sufficient to overturn the conviction.

Question: Which documentary and material evidence should be collected and examined before filing the appeal to demonstrate the absence of corroboration and to support a bail application?

Answer: The first step for any lawyer in Punjab and Haryana High Court is to obtain the complete FIR, the trial court judgment, the transcript of the approver’s testimony and the charge sheet filed by the investigating agency. These documents establish the factual allegations and the evidentiary basis of the conviction. Next, the defence should request the purchase register of the chemical supplier, the sales invoices of the sweet shop and any bank statements that could show a transaction for the alleged poison. The absence of such records will be a strong indicator of non‑corroboration. Forensic reports, if any, relating to the toxic substance recovered from the victim’s remains or from the sweets should be examined; a missing report or a negative finding will further weaken the prosecution’s case. Witness statements of shopkeepers, neighbours or delivery personnel who might have seen the accused handling the material are also crucial; their non‑existence or refusal to testify can be highlighted. In addition, the defence should secure the medical certificate of the accused confirming any health condition that may affect his ability to handle toxic chemicals, as this can be used to argue against the likelihood of participation. All these documents must be organized into a bundle that the appellate counsel can present to the bench to illustrate the evidentiary vacuum. For a bail application, the same bundle demonstrates that the conviction is predicated on shaky foundations, thereby reducing the perceived flight risk. Moreover, the bail petition should reference the fact that the accused has been in custody for an extended period without substantive proof, invoking the principle that liberty is the rule and detention is the exception. Lawyers in Chandigarh High Court frequently stress that a well‑prepared dossier showing the lack of documentary corroboration not only strengthens the appeal but also persuades the court to grant interim relief in the form of bail pending the determination of the appeal.

Question: What procedural defect arises from the trial court’s admission of the approver’s testimony and how can the appellate court rectify it?

Answer: The procedural defect lies in the trial court’s failure to apply the mandatory test that requires independent corroboration of each material allegation made by an approver. By admitting the testimony without demanding proof of the accused’s procurement of the poison, preparation of the sweets and delivery to the victim’s residence, the court overlooked a safeguard designed to prevent convictions on unreliable statements. A lawyer in Punjab and Haryana High Court would argue that this omission constitutes a breach of the principle that the prosecution bears the burden of proving every essential element of the offence beyond reasonable doubt. The appellate brief should point out that the trial judge did not record any finding of corroboration on the material points, nor did the judge invite the defence to challenge the reliability of the approver. The High Court has the authority to review the trial court’s discretion in admitting evidence and can set aside the judgment if it finds that the admission was illegal or perverse. The remedy sought would be either a complete quashing of the conviction on the ground of inadmissible evidence or a remand for a fresh trial where the State must satisfy the corroboration requirement. The appellate court may also direct the investigating agency to re‑examine the evidence and to file a supplementary charge sheet if new material emerges. By correcting the procedural defect, the High Court restores the balance of the adversarial process and upholds the constitutional guarantee of a fair trial. Lawyers in Chandigarh High Court often advise that the appeal should include a detailed comparison of the trial court’s reasoning with the established jurisprudence on approver evidence, thereby demonstrating that the lower court’s decision was not in line with precedent and must be reversed.

Question: How should the defence address the custodial hardship faced by the accused and what are the key considerations for securing bail pending the outcome of the appeal?

Answer: The accused has been detained since the investigation stage and continues to serve a sentence imposed by the Sessions Court. The custodial hardship is amplified by the fact that the conviction rests on uncorroborated testimony. A lawyer in Punjab and Haryana High Court would begin by filing an application for bail on the grounds of the absence of substantive evidence, the prolonged nature of the detention and the presumption of innocence until the appeal is decided. The application must demonstrate that the accused is not a flight risk, has stable family ties, and is unlikely to tamper with evidence because the prosecution’s case is weak. The defence should also highlight the health implications of continued imprisonment, especially if the accused suffers from any medical condition documented in a doctor’s certificate. The High Court, when considering bail, will weigh the seriousness of the alleged offence against the strength of the prosecution’s case; the lack of corroboration tilts the balance in favour of liberty. Additionally, the bail order can be conditioned on the accused’s surrender of passport, regular reporting to the police station and a prohibition on contacting witnesses. Lawyers in Chandigarh High Court often stress that securing bail not only alleviates the immediate hardship but also enables the accused to actively participate in the preparation of the appeal, including gathering fresh evidence and coordinating with investigators. The practical implication is that a successful bail application preserves the accused’s freedom, reduces the psychological pressure of incarceration and enhances the ability to mount an effective defence at the appellate stage.

Question: In what ways can the defence reshape the narrative of the accused’s alleged role in procuring the poison and preparing the sweets to create reasonable doubt?

Answer: The defence strategy should focus on dismantling the prosecution’s core assertions that the accused personally obtained the toxic substance, mixed it into the confectionery and handed it over to the intermediary. First, the counsel can argue that the purchase of the poison was never documented in any register or receipt bearing the accused’s signature, and that the alleged signature on the supplier’s ledger is contested. Second, the defence can present evidence that the accused had no prior experience in handling chemicals or preparing sweets, making it implausible that he could have carried out the alleged act without assistance. Third, the defence may introduce testimony from friends or family members who attest that the accused was abroad or otherwise occupied at the time of the alleged procurement, thereby providing an alibi. Fourth, the defence can highlight the role of the intermediary who turned approver, emphasizing that the intermediary had the motive to shift blame and that his testimony is self‑serving. By raising these points, the defence creates a narrative that the accused’s involvement, if any, was peripheral at most, and that the State has not met its burden of proving the essential elements beyond reasonable doubt. A lawyer in Chandigarh High Court would advise that the appeal brief should meticulously juxtapose the uncorroborated allegations with the lack of documentary proof and the presence of alternative explanations. The practical implication is that the High Court, when faced with reasonable doubt, is likely to either set aside the conviction or order a retrial, thereby safeguarding the accused’s right to be presumed innocent until proven guilty.