Ram Pratap Acquitted: Supreme Court Overturns Murder Conviction
The case of Ram Pratap vs. The State of Haryana was an appeal before the Supreme Court of India against the conviction of the appellant under Section 302 of the Indian Penal Code (IPC). The High Court of Punjab and Haryana had upheld the life imprisonment sentence, though it had set aside the appellant’s conviction under Section 120-B IPC. The Supreme Court, in its judgment, acquitted Ram Pratap of all charges.
The case revolves around the alleged murder of Om Prakash, who was last seen with the accused. The prosecution relied on circumstantial evidence, but the Supreme Court found inconsistencies and weaknesses in the evidence, leading to the acquittal of the appellant.
Facts of the Case
The prosecution’s case was built on the following sequence of events:
- Om Prakash, the deceased, was on visiting terms with Ram Pratap.
- On December 13, 2007, at 10:00 AM, Ram Pratap visited Om Prakash’s house, and they left together after having tea.
- At midnight, Ram Pratap and others brought Om Prakash’s dead body to his house in a jeep.
- Jagdish Chander (PW-4), the brother of the deceased, registered an FIR after 14 hours, expressing suspicion against Ram Pratap.
- A chargesheet was filed against four accused, including the appellant.
Arguments by the Petitioner (Ram Pratap)
The petitioner’s counsel, Mayank Dahiya, contended that the conviction was based purely on circumstantial evidence, and the prosecution failed to prove guilt beyond a reasonable doubt. The main arguments were:
- The only witness who claimed to have seen Ram Pratap with the deceased (PW-5) turned hostile.
- There was an unexplained delay of 14 hours in lodging the FIR.
- The trial court acquitted the other accused based on the same evidence, yet convicted Ram Pratap, which was contradictory.
- There was no direct evidence linking the appellant to the crime.
Arguments by the Respondent (State of Haryana)
The counsel for the State of Haryana, Dinesh Chander Yadav, argued that the conviction was justified, stating:
- The High Court and the trial court correctly appreciated the evidence.
- Though PW-5 turned hostile, the testimony of PW-4 was sufficient.
- Ram Pratap was last seen with the deceased, and he returned with the dead body.
- There was a strong suspicion against the appellant.
Supreme Court’s Observations
The Supreme Court held that suspicion, however strong, cannot substitute proof beyond reasonable doubt. The Court referred to the landmark case Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116, emphasizing:
“There is not only a grammatical but also a legal distinction between ‘may’ and ‘must.’ For proving a case based on circumstantial evidence, it is necessary for the prosecution to establish each and every circumstance beyond reasonable doubt.”
The Court highlighted the following points:
- The statement of PW-4 that Ram Pratap admitted to killing Om Prakash was not mentioned in the oral complaint.
- The 14-hour delay in lodging the complaint was not sufficiently explained.
- The only witness supporting the last-seen theory (PW-5) turned hostile, making the prosecution’s case weak.
- The trial court disbelieved the same evidence while acquitting the other accused but relied on it to convict Ram Pratap, which was inconsistent.
Supreme Court’s Verdict
On these grounds, the Supreme Court allowed the appeal, stating:
“In the present case, the evidence on record does not establish the guilt of the appellant beyond reasonable doubt. Mere suspicion or conjecture cannot form the basis of conviction.”
The Court acquitted Ram Pratap of all charges and ordered the cancellation of his bail bonds.
Petitioner Name: Ram Pratap.Respondent Name: The State of Haryana.Judgment By: Justice B. R. Gavai, Justice Vikram Nath.Place Of Incident: Haryana.Judgment Date: 01-12-2022.
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