Supreme Court Reinstates Conviction in Murder Case: Key Arguments and Analysis

The Supreme Court of India recently delivered a significant judgment in the criminal appeals filed by the State of Uttar Pradesh against the acquittal of Satendra and Neetu by the High Court. The case revolves around a brutal incident that occurred in the dead of night on January 31, 2004, in the village of Budana, Muzzafarnagar, Uttar Pradesh. The Supreme Court, after a thorough examination of the evidence and arguments, overturned the High Court’s decision and reinstated the convictions of the respondents under various sections of the Indian Penal Code (IPC). Here’s a detailed breakdown of the case, the arguments presented, and the Court’s reasoning.

Background of the Case

The incident took place at the house of Lakshman Singh (PW-3), where his family, including his sons Rajveer Singh (PW-1), Rajpal Singh (PW-2), and the deceased Dharampal, were residing. According to the prosecution, a group of miscreants, including Satendra and Neetu, broke into the house at midnight. The intruders allegedly attacked the family, resulting in the death of Dharampal due to a gunshot wound. The trial court convicted Satendra and Neetu under Sections 148, 450/149, 323/149, 307/149, and 302/149 of the IPC. However, the High Court acquitted them, citing discrepancies in the testimonies of the eyewitnesses.

Key Arguments by the State (Appellant)

The State of Uttar Pradesh, represented by its counsel, argued that the High Court erred in disregarding the consistent testimonies of the three eyewitnesses—Rajveer Singh (PW-1), Rajpal Singh (PW-2), and Lakshman Singh (PW-3). The State emphasized that the FIR, registered immediately after the incident, clearly named Satendra and Neetu as the perpetrators. The State also highlighted the following points:

The eyewitnesses identified the accused despite the chaotic situation, owing to the light from a torch and lantern.
The FIR was registered promptly, and the names of the accused were mentioned without delay, indicating the reliability of the prosecution’s case.
The postmortem report (Exhibit-Ka. 3) confirmed that Dharampal died due to a gunshot injury, corroborating the eyewitness accounts.

Key Arguments by the Respondents (Satendra and Neetu)

The respondents’ counsel argued that the High Court’s acquittal was justified due to several discrepancies in the prosecution’s case. Their arguments included:

Discrepancies in the eyewitness testimonies regarding whether the accused had muffled their faces during the incident.
The ballistic report (Exhibit-Ka. 26) did not match the recovered cartridges with the pistol allegedly used by Satendra, casting doubt on his involvement.
Neetu was not initially charge-sheeted and was only summoned later under Section 319 of the Code of Criminal Procedure, 1973, raising questions about the prosecution’s consistency.

Supreme Court’s Analysis and Decision

The Supreme Court, after carefully reviewing the evidence, rejected the High Court’s reasoning and reinstated the convictions. The Court made the following key observations:

1. Reliability of Eyewitness Testimonies

The Court noted that minor discrepancies in the testimonies of rustic villagers, who were suddenly confronted with a violent intrusion, were natural and did not undermine their credibility. The Court stated:

“We not only find the above reasoning contradictory, but on reading the testimonies of Rajveer Singh (PW-1), Rajpal Singh (PW-2) and Lakshman Singh (PW-3), we are of the opinion that they have been forthright about the facts in the versions stated by them.”

2. Prompt Registration of FIR

The Court emphasized that the FIR was registered within hours of the incident, and the names of the accused were clearly mentioned. This, according to the Court, lent credibility to the prosecution’s case.

3. Ballistic Report and Recovery of Weapons

The Court acknowledged that the ballistic report did not match the recovered cartridges with the pistol allegedly used by Satendra. However, it held that this did not negate the eyewitness accounts, as the police might have failed to recover the actual weapon used in the crime.

4. Conduct of the Eyewitnesses

The Court rejected the argument that the eyewitnesses’ act of confronting armed miscreants was unnatural. It observed:

“We are dealing with villagers who were perturbed when they found intruders entering their house to commit dacoity and attacking their father, Lakshman Singh (PW-3).”

Final Judgment

The Supreme Court convicted Satendra and Neetu under Sections 323, 450, 307, and 302 read with Section 34 of the IPC. The sentences imposed were as follows:

Section 302 IPC: Life imprisonment and a fine of ₹10,000/- each.
Section 307 IPC: 5 years of rigorous imprisonment and a fine of ₹5,000/- each.
Section 450 IPC: 5 years of rigorous imprisonment and a fine of ₹5,000/- each.
Section 323 IPC: 1 year of rigorous imprisonment.

The Court directed the respondents to surrender within four weeks to serve their sentences.

Conclusion

The Supreme Court’s judgment underscores the importance of evaluating eyewitness testimonies in the context of the situation and rejecting hyper-technical discrepancies that do not affect the core of the prosecution’s case. The decision reaffirms the principle that justice must prevail, especially in cases involving heinous crimes like murder.

Petitioner Name: The State of Uttar Pradesh.
Respondent Name: Satendra, etc..
Judgment By: Justice SANJIV KHANNA, Justice SANJAY KUMAR.
Place Of Incident: Budana, Muzzafarnagar, Uttar Pradesh.
Judgment Date: 19-03-2025.

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