Supreme Court Acquits Accused in Haryana Murder Case Citing Lack of Evidence
The case of Mohd. Rijwan v. State of Haryana brings to light the importance of proper judicial procedures and the burden of proof in criminal trials. The Supreme Court carefully examined the evidence and found that the prosecution failed to establish guilt beyond a reasonable doubt, leading to the appellant’s acquittal.
Background of the Case
The appellant, Mohd. Rijwan, was convicted by the Sessions Court under Sections 302 and 201 read with Section 34 of the Indian Penal Code (IPC) for the murder of one Vidya Sagar alias Bhushan. He was sentenced to life imprisonment for murder and three years of rigorous imprisonment for destroying evidence. The High Court upheld this conviction. However, upon appeal, the Supreme Court re-examined the case and found inconsistencies in the prosecution’s case, ultimately acquitting the appellant.
Allegations Against the Accused
The case was based on circumstantial evidence, with two primary claims made by the prosecution:
- The deceased was last seen alive with the appellant.
- The appellant’s confession led to the recovery of the deceased’s body.
According to the prosecution, the deceased was last seen with the appellant on February 17, 2004. The two had allegedly consumed alcohol together before the appellant and his accomplices murdered the deceased, buried the body near a hand pump, and covered it with soil.
Key Evidence Presented by the Prosecution
The prosecution relied on witness testimony and the discovery of the deceased’s body. Two witnesses, Pyare Lal (PW-6) and Radhey Shyam (PW-9), were crucial to the case. Pyare Lal testified:
“On 17.2.2004, at about 4 p.m., accused Mohd. Rizwan came to my shop on a black-colored motorcycle with Vidya Sagar as a pillion rider. They had both consumed liquor. The accused struck his motorcycle into my feet. When I cried for help, some people, including Hari Chand Sharma, intervened and settled the matter. The accused gave me Rs. 50 for medicine and then left with Vidya Sagar.”
Inconsistencies in the Prosecution’s Case
The Supreme Court identified several inconsistencies in the prosecution’s claims, including:
- PW-6 admitted that he did not know the appellant before the alleged incident and could only describe his appearance.
- Before formally identifying the accused in court, PW-6 was taken to the Superintendent of Police’s office and shown the appellant, compromising the credibility of the identification process.
- PW-9, who worked with the appellant, testified that on the day of the alleged murder, the appellant was at a worksite from 3 p.m. to 5 p.m., contradicting PW-6’s statement.
- The police failed to conduct a proper test identification parade, which is necessary when the witness does not previously know the accused.
- The prosecution did not produce an important witness, Hari Chand Sharma, who was allegedly present when the deceased was last seen alive.
Supreme Court’s Observations
The Supreme Court scrutinized the evidence and noted:
“A test identification parade is conducted when an eyewitness does not know the accused before the incident. In this case, instead of holding a proper parade, PW-6 was shown the appellant at the Superintendent of Police’s office. This identification process is not legally acceptable and creates doubts about the credibility of the witness.”
The Court further observed:
“The testimony of PW-9 contradicts the prosecution’s claim that the accused was last seen with the deceased at 4 p.m. This casts serious doubts on the reliability of PW-6’s statement.”
Final Judgment
Due to these inconsistencies and procedural errors, the Supreme Court ruled in favor of the appellant:
“We hold that the prosecution has failed to prove the charges against the appellant beyond a reasonable doubt. Therefore, the appeal succeeds, and the impugned judgment is set aside. The appellant is acquitted of the offence alleged against him.”
Implications of the Judgment
This case highlights the importance of proper identification procedures, the necessity of corroborating evidence, and the burden of proof in criminal trials. The judgment reinforces the principle that circumstantial evidence must form a complete chain of events leading to the accused’s guilt. Any missing links, as seen in this case, create reasonable doubt and warrant acquittal.
The Supreme Court’s ruling serves as a reminder that courts must rigorously examine prosecution evidence and uphold procedural fairness to prevent wrongful convictions.
Petitioner Name: Mohd. Rijwan.Respondent Name: State of Haryana.Judgment By: Justice Abhay S. Oka, Justice Pankaj Mithal.Place Of Incident: Haryana.Judgment Date: 13-10-2023.
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