Supreme Court Acquits Accused in Murder Case: Lack of Evidence and Doubt Benefit Defendants

The Supreme Court of India recently ruled in the case of Machindra v. Sajjan Galpha Rankhamb & Ors., where the accused were acquitted due to lack of conclusive evidence. The case, which involved a murder stemming from a family dispute, highlights the importance of the ‘beyond reasonable doubt’ standard in criminal trials.

The judgment overturned the trial court’s conviction of the accused and upheld the Bombay High Court’s ruling, emphasizing the need for reliable eyewitness testimony, forensic evidence, and consistency in prosecution claims.

Background of the Case

The case involved a family dispute over land ownership. The appellant, Machindra, had purchased three acres of land from his father-in-law nearly two decades before the incident. This transaction led to hostility between him and the accused, who were his in-laws. The key individuals in the case were:

Appellant: Machindra (father of the deceased, complainant)
Accused: Sajjan Galpha Rankhamb (brother-in-law of the appellant) and his son Kakasaheb
Victim: Dattatreya (Machindra’s son)

On April 21, 2007, Machindra’s family attended a wedding, leaving Dattatreya alone at home. Upon returning, they found him dead in a field, reportedly attacked with a stick and a yoke pin. A neighbor, Balu Shekha Solawar, informed them that the accused had committed the murder.

Petitioner’s Argument

Machindra, the complainant, presented the following arguments:

His son was brutally attacked by the accused, resulting in fatal injuries.
Witnesses had seen the accused attacking the victim.
There was a history of enmity between the families, providing motive.
The trial court’s conviction was based on reliable evidence and should be upheld.

Respondent’s Argument

The defense, led by Sajjan Galpha Rankhamb and his son, countered with the following points:

The prosecution’s witnesses were unreliable and had contradictory statements.
Medical evidence did not conclusively link them to the crime.
The Investigating Officer had not recorded eyewitnesses to the crime.
There was an unexplained six-day delay in filing the First Information Report (FIR).
Forensic evidence, such as weapon analysis, was missing.

Trial Court’s Verdict

The trial court found the accused guilty under Section 302 read with Section 34 of the Indian Penal Code (IPC) and sentenced them to life imprisonment. The decision was based on:

Eyewitness testimonies of PW-3, PW-4, and PW-10.
Medical evidence confirming head injuries on the deceased.
Recovery of the alleged murder weapons at the instance of the accused.

High Court’s Reversal

The accused challenged the conviction in the Bombay High Court, which reversed the decision and acquitted them, stating:

The prosecution had failed to prove the case beyond reasonable doubt.
Eyewitness testimonies were contradictory and unreliable.
The investigating officer had not recorded statements from direct eyewitnesses.
The six-day delay in filing the FIR was unexplained.
Medical evidence did not confirm whether the injuries were caused by the recovered weapons.

Supreme Court’s Observations

The Supreme Court, comprising Justices Pinaki Chandra Ghose and Rohinton Fali Nariman, upheld the High Court’s acquittal, making the following key observations:

1. Conviction Must Be Based on Conclusive Evidence

“It is a cardinal principle of criminal jurisprudence that the guilt of the accused must be proved beyond all reasonable doubts. However, the burden on the prosecution is only to establish its case beyond all reasonable doubt and not all doubts.”

The Court emphasized that the prosecution failed to present a consistent case.

2. Unreliable Eyewitnesses Cannot Form the Basis of Conviction

“We have noticed that there are contradictions in the depositions of PW-4 and PW-10 and none of them is an eyewitness to the alleged incident.”

The testimonies of key witnesses were inconsistent and did not establish the accused’s direct involvement.

3. Unexplained Delay in FIR Weakens the Case

The Supreme Court found the six-day delay in filing the FIR to be unjustified, raising doubts about the prosecution’s version.

4. Medical Evidence Was Inconclusive

“A medical witness who performs a post-mortem examination is a witness of fact. If the cause of injuries is not stated, the prosecution case weakens significantly.”

The post-mortem report did not conclusively determine if the injuries were caused by the weapons recovered from the accused.

Judgment

The Supreme Court upheld the acquittal and ruled:

The prosecution had failed to establish guilt beyond a reasonable doubt.
All circumstantial evidence raised substantial doubts rather than proving guilt.
The accused were entitled to the benefit of the doubt.
The trial court’s decision was overturned, and the accused were acquitted of all charges.

Implications of the Judgment

This ruling reinforces key principles in criminal law:

1. Burden of Proof on Prosecution

The prosecution must establish guilt beyond reasonable doubt, not just raise suspicion.
Any inconsistencies in evidence favor the accused.

2. Importance of Reliable Eyewitnesses

Courts rely heavily on credible eyewitness testimony.
Contradictory statements weaken the prosecution’s case.

3. Role of Medical and Forensic Evidence

Post-mortem reports must provide clear cause of death.
Weapons recovered must conclusively match injuries found on the victim.

4. FIR Delay Raises Doubts

A delayed FIR without explanation can weaken a case.
Timely reporting strengthens prosecution claims.

Conclusion

The Supreme Court’s ruling in Machindra v. Sajjan Galpha Rankhamb & Ors. reinforces the fundamental principles of criminal justice. It ensures that no person is convicted based on weak or speculative evidence, emphasizing that justice must be based on concrete and reliable proof.

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Download Judgment: Machindra vs Sajjan Galpha Rankha Supreme Court of India Judgment Dated 19-04-2017.pdf

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