Murder Conviction Upheld: Supreme Court Rules on Eyewitness Testimonies and Common Intention

The case of Karulal & Ors. v. The State of Madhya Pradesh involves the conviction of five accused under Section 148 and Section 302 read with Section 149 of the Indian Penal Code (IPC) for the murder of one Madhavji. The Supreme Court was tasked with determining whether the High Court of Madhya Pradesh correctly upheld their conviction based on eyewitness testimonies, medical evidence, and the principle of common intention under Section 149 IPC.

Background of the Case

The incident occurred on August 18, 1993, when the deceased, Madhavji, was attacked while working in his field. His son, Bhanwarlal (PW3), witnessed the attack and rushed to his father’s aid. The accused, armed with weapons like axes, swords, lathis, and farsas, inflicted fatal injuries. Despite efforts to transport Madhavji to the hospital, he succumbed to his injuries en route.

The prosecution’s case was primarily built on the eyewitness accounts of Bhanwarlal (PW3), Babulal (PW11), and Shyamkalabai (PW12), along with the medical evidence presented by Dr. P.N. Shrivastav (PW2). The trial court convicted the accused, which was later upheld by the High Court. The accused then filed an appeal before the Supreme Court.

Key Legal Issues

Whether the eyewitness testimonies were reliable and corroborated by medical evidence.
Whether the conviction under Section 149 IPC was justified.
Whether the defense’s claim of false implication due to past enmity was tenable.

Arguments by the Petitioners

The appellants contended:

The prosecution witnesses were related to the deceased and thus not independent.
There were minor discrepancies in the eyewitness statements.
The injuries sustained by the deceased could have been the result of an accidental fall into a nullah.
The trial court and High Court failed to consider the defense witnesses.

Arguments by the Respondent

The State of Madhya Pradesh countered:

The eyewitness accounts were consistent and corroborated by medical evidence.
The presence of multiple injuries inflicted by sharp-edged and blunt weapons ruled out an accidental fall.
The accused were part of an unlawful assembly with a common intention to cause death, justifying their conviction under Section 149 IPC.

Supreme Court’s Analysis

1. Reliability of Eyewitness Testimonies

The Supreme Court reaffirmed the principle that merely being related to the deceased does not render a witness unreliable. It cited Dalip Singh v. State of Punjab (1953) and State of Uttar Pradesh v. Samman Dass (1972), stating:

“A witness is normally to be considered independent unless they spring from sources likely to be tainted.”

The Court found no reason to disbelieve the testimonies of Bhanwarlal (PW3), Babulal (PW11), and Shyamkalabai (PW12).

2. Medical Evidence and Cause of Death

Dr. P.N. Shrivastav (PW2) conducted the post-mortem examination and identified nine injuries on the deceased, including:

Incised wounds on the head and upper limbs.
Fractures of the tibia, fibula, radius, and ulna.
Severed femoral artery leading to excessive blood loss.

The doctor opined that the injuries could not have been caused by an accidental fall, reinforcing the prosecution’s case.

3. Application of Section 149 IPC

The Court upheld the conviction under Section 149 IPC, explaining:

“When an unlawful assembly shares a common objective to commit an offense, each member is vicariously liable for the actions of the others.”

Given that the accused were armed and collectively attacked the victim, their conviction under Section 302 read with Section 149 IPC was justified.

4. Defense’s Claim of False Implication

The defense argued that enmity between the accused and the deceased’s family led to false implication. However, the Court held:

“Enmity is a double-edged sword; while it may provide motive, it does not necessarily indicate false implication.”

The Court found no merit in the defense’s claim.

Final Verdict

The Supreme Court dismissed the appeal, upholding the conviction and sentencing of the accused to life imprisonment. The key reasons were:

Eyewitness testimonies were credible and consistent.
Medical evidence corroborated the prosecution’s version.
The accused acted with a common intention to kill the deceased.
No substantial evidence supported the claim of false implication.

Implications of the Judgment

This ruling reinforces several legal principles:

Eyewitness testimonies, even from related persons, can be reliable if consistent and corroborated.
Medical evidence plays a crucial role in validating eyewitness accounts.
Section 149 IPC imposes vicarious liability on members of an unlawful assembly.
Defense claims of false implication must be backed by substantial evidence.

The decision upholds the importance of fair trials based on substantive evidence and legal principles.

Petitioner Name: Karulal & Ors..
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice Hrishikesh Roy.
Place Of Incident: Mandsaur, Madhya Pradesh.
Judgment Date: 09-10-2020.

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