Acquittal in Murder Case: Supreme Court Overturns Conviction Due to Lack of Evidence

The case of Pankaj v. State of Rajasthan highlights an important legal discussion about the reliability of witness testimony, forensic evidence, and the necessity of proving guilt beyond a reasonable doubt. The Supreme Court overturned the conviction of the accused due to inconsistencies in prosecution evidence and procedural lapses.

Background of the Case

The case originated from an incident on 19th March 1998, when an FIR was filed by Ram Babu, stating that his brother Raj Kumar was shot by the appellant, Pankaj. According to the complaint, Pankaj, along with three others, visited Ram Babu’s juice shop and called Raj Kumar inside. It was alleged that Pankaj fired a shot at Raj Kumar using a country-made pistol, which hit him in the neck, leading to his death on 25th March 1998.

A case was registered under Sections 302, 452, and 34 of the IPC, along with Section 3 read with Section 25 of the Arms Act. The trial court convicted Pankaj and sentenced him to life imprisonment, while the High Court upheld the conviction. However, the Supreme Court, after examining inconsistencies in the prosecution’s case, overturned the conviction.

Arguments from the Appellant (Pankaj)

• The appellant argued that there was no motive behind the killing of Raj Kumar.
• The sole eyewitness, Ram Babu (PW-8), was an interested witness, and his testimony had contradictions.
• The recovery of the firearm was false and had been planted by the police.
• The prosecution failed to establish a strong case against the accused beyond a reasonable doubt.

Arguments from the Respondent (State of Rajasthan)

• The prosecution contended that Ram Babu’s testimony was corroborated by Shyam Sunder (PW-5), making it credible.
• The firearm was recovered at the instance of the appellant, strengthening the case against him.
• The evidence presented was sufficient to uphold the conviction.

Supreme Court’s Judgment

1. Inconsistencies in Eyewitness Testimony

The Supreme Court found significant inconsistencies in the testimony of PW-8 (Ram Babu). He stated that the accused and the victim were sitting close to each other when the shot was fired. However, medical evidence contradicted this claim.

According to Dr. Vanay Singh (PW-6), the absence of burning, blackening, or tattooing around the wound indicated that the shot was fired from a distance of more than three feet. This directly contradicted PW-8’s claim that the accused fired at close range.

2. Questionable Forensic Evidence

The forensic report stated that the bullet recovered from the scene was not fired from the pistol allegedly recovered from the accused. This raised doubts about the authenticity of the firearm recovery and its connection to the crime.

3. Unreliable Dying Declaration

The prosecution relied on a dying declaration recorded at 10:45 PM on the day of the incident. However, medical records showed that the victim was unconscious earlier that day. The absence of a certification from the attending doctor regarding the victim’s fitness to make a statement made the dying declaration unreliable.

4. Failure to Prove Motive

While motive is not always necessary for conviction, the prosecution’s failure to establish why the accused would commit the murder weakened its case. The theory that Pankaj killed Raj Kumar over a minor dispute regarding unpaid juice bills seemed implausible.

5. Failure to Follow Proper Investigation Procedures

• The blood-stained clothes of PW-8 were not seized by the police, raising questions about the thoroughness of the investigation.
• There was no satisfactory explanation for why the police did not collect stronger evidence linking the accused to the crime.

Final Ruling

The Supreme Court concluded that the prosecution failed to prove guilt beyond a reasonable doubt. The Court held:

“When the genesis and the manner of the incident is doubtful, the accused cannot be convicted. The prosecution has failed to establish the circumstances in which the appellant was alleged to have fired at the deceased.”

Accordingly, the conviction was set aside, and Pankaj was acquitted.

Key Takeaways from the Judgment

• Medical and forensic evidence must align with eyewitness testimony for a conviction to be sustained.
• A dying declaration must be free from doubts regarding the victim’s consciousness and ability to provide a statement.
• The prosecution must prove guilt beyond a reasonable doubt, especially in serious offenses like murder.
• Improper investigation and procedural lapses can weaken the prosecution’s case.

Conclusion

The Supreme Court’s ruling in Pankaj v. State of Rajasthan reinforces the principle that an accused cannot be convicted based on weak or contradictory evidence. This case serves as a reminder of the importance of due process, proper investigation, and adherence to legal standards in criminal trials.

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Download Judgment: Pankaj vs State of Rajasthan Supreme Court of India Judgment Dated 09-09-2016-1741883706603.pdf

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