Acquittal in Murder Case: Supreme Court Upholds High Court’s Verdict

The Supreme Court of India, in its judgment dated August 16, 2018, ruled on an appeal filed by the State of Karnataka challenging the acquittal of two accused individuals in a murder case. The case, State of Karnataka vs. P. Ravikumar @ Ravi & Ors., revolved around the alleged murder of Mohan Kumar by his wife and her accomplices. The trial court had convicted all three accused, but the High Court acquitted two of them, leading to the appeal before the Supreme Court.

The case was based on circumstantial evidence, including extra-judicial confessions and the recovery of photographs suggesting an illicit relationship. The Supreme Court examined whether the evidence was sufficient to overturn the High Court’s acquittal and reinstate the convictions.

Prosecution’s Case

The prosecution alleged that the murder was a conspiracy involving the deceased’s wife, D.B. Savitha (Accused No. 3), and her accomplices, P. Ravikumar (Accused No. 2) and another individual (Accused No. 1). The motive was reportedly the victim’s objections to his wife’s illicit relationship with Accused No. 1.

On July 7, 2003, the deceased, Mohan Kumar, left for his fertilizer shop and never returned home. His body was later found by the roadside, with initial reports suggesting a motorcycle accident. However, further investigation led to allegations of murder.

Petitioner’s Arguments

The State of Karnataka argued that the High Court had erred in acquitting the two accused, emphasizing that the circumstantial evidence pointed to their involvement. The prosecution relied on:

• An extra-judicial confession made by Accused No. 2 to PW-2, an auto driver and friend of the accused.
• The testimony of PW-4, who claimed that Accused No. 2’s clothes were blood-stained on the night of the murder.
• Photographs (Exhibit P-8 & P-9) recovered from Accused No. 3, showing her with Accused No. 1, allegedly proving their illicit relationship and suggesting a motive.

Respondent’s Arguments

The defense argued that the evidence was weak and insufficient to sustain a conviction. Key points included:

• PW-2, the auto driver, turned hostile during cross-examination, making his extra-judicial confession unreliable.
• PW-4’s statement about the blood-stained clothes did not directly link Accused No. 2 to the crime.
• The photographs only suggested a relationship but did not prove a conspiracy to commit murder.

Supreme Court’s Observations

The Supreme Court noted that the prosecution’s case relied heavily on circumstantial evidence and extra-judicial confessions, which are inherently weak forms of evidence. The Court stated:

“In any event, extra-judicial confession is a weak piece of evidence, which cannot form the basis for conviction unless supported by other substantive evidence, which is lacking in this case.”

The Court further observed that the High Court had already evaluated the evidence and found it insufficient to establish guilt beyond a reasonable doubt. It emphasized the principle that an acquittal should not be overturned unless there are compelling reasons to do so.

Final Verdict

In its final ruling, the Supreme Court dismissed the appeal, stating:

“Upon appreciation of the evidence adduced by the prosecution, the High Court has held that the guilt of Accused Nos. 2 and 3 has not been established beyond reasonable doubt. We do not find any ‘compelling reason’ or ‘substantial infirmity’ warranting interference with the order of acquittal.”

Conclusion

The judgment in State of Karnataka vs. P. Ravikumar @ Ravi & Ors. reinforces the principle that extra-judicial confessions alone cannot be the basis of conviction. The ruling underscores the importance of proving guilt beyond a reasonable doubt and affirms the High Court’s decision to acquit the accused due to lack of substantial evidence.

Petitioner Name: State of Karnataka.
Respondent Name: P. Ravikumar @ Ravi & Ors..
Judgment By: Justice R. Banumathi, Justice Vineet Saran.
Place Of Incident: Karnataka, India.
Judgment Date: 16-08-2018.

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