Acquittal in Murder Case: Supreme Court’s Ruling on Circumstantial Evidence and Legal Standards

The case of Devi Lal & Another vs. State of Rajasthan revolves around the conviction of the appellants for murder under Section 302 of the Indian Penal Code (IPC), which was subsequently challenged in the Supreme Court. The appellants were accused of conspiring to murder Dharam Chand, and their conviction was based on circumstantial evidence. The Supreme Court ultimately acquitted the appellants, emphasizing the importance of establishing a strong and coherent chain of circumstantial evidence to prove the guilt of the accused beyond a reasonable doubt.

The case emerged from a dispute over financial transactions and personal conflicts involving the accused and the deceased. The prosecution’s case relied on the circumstantial evidence of a motive, the recovery of evidence, and an alleged extra-judicial confession by one of the accused. However, the Supreme Court found that the evidence presented by the prosecution was not sufficient to support the conviction, as it failed to meet the legal standards required for a criminal conviction.

Background of the Case

The complainant, Vijay Singh (PW-2), reported the disappearance of his cousin, Dharam Chand, on 8th February 1999. Dharam Chand, who had gone to Bhagwanpura on his motorcycle, was last seen on the evening of 7th February. His body was later discovered in a dry well, and the investigation revealed that he had been murdered. The prosecution claimed that the appellants, Devi Lal and Babu Lal, were involved in the conspiracy and murder of the deceased. The motive was allegedly related to a financial dispute and previous altercations involving the deceased and the accused.

The investigation also revealed that the accused were in possession of certain items that could be linked to the crime, including a torn page from a ledger that allegedly had the signature of the deceased. Based on these findings, the appellants were charged with murder under Section 302 and conspiracy under Section 120B of the IPC.

Petitioner’s Arguments

The appellants argued that:

• The case against them was based on circumstantial evidence, which was weak and insufficient to establish their guilt beyond reasonable doubt.
• The extra-judicial confession made by Babu Lal was unreliable, as it was not corroborated by any other solid evidence.
• The recovery of the torn leaf from the ledger and other evidence was highly suspicious and did not conclusively link them to the crime.
• The prosecution failed to establish a clear motive for the murder, and the evidence presented did not show that the appellants were the only persons who could have committed the crime.

Respondent’s Arguments

The prosecution argued that:

• The appellants had a clear motive to kill the deceased due to previous financial disputes and personal animosity.
• Witnesses, including PW-5 and PW-10, testified to the involvement of the appellants in the crime.
• The extra-judicial confession made by Babu Lal was admissible and provided a strong link between the accused and the crime.
• The circumstantial evidence, when taken together, pointed to the guilt of the appellants beyond reasonable doubt.

Supreme Court’s Observations and Ruling

The Supreme Court ruled in favor of the appellants, overturning their conviction. The key observations made by the Court were:

1. Weakness of Circumstantial Evidence

The Court emphasized that the prosecution’s case rested entirely on circumstantial evidence, which failed to establish a coherent and complete chain of events:

“The prosecution must establish all the circumstances beyond reasonable doubt, and the circumstances must lead to an inevitable conclusion that the accused alone is responsible for the crime.”

The Court found that the evidence was not sufficient to eliminate the possibility of the appellants’ innocence.

2. Issues with Extra-Judicial Confession

The Court noted that extra-judicial confessions are often unreliable, especially when not supported by corroborative evidence:

“Extra-judicial confessions are weak evidence and should be corroborated by other circumstantial evidence. In the absence of such corroboration, the confession alone cannot be relied upon for conviction.”

The Court found that the confession made by Babu Lal was not supported by any other solid evidence.

3. Lack of Clear Motive

The Court observed that the motive presented by the prosecution was weak and did not provide sufficient grounds for murder:

“The circumstances related to the alleged motive are insufficient to establish that the accused would commit murder over such trivial disputes.”

The Court found that the financial disputes and personal conflicts, while contributing to suspicion, were not strong enough to justify the murder.

4. Doubts Over the Recovery of Evidence

The Court criticized the recovery of the torn ledger page, stating:

“The recovery of the torn leaf from the ledger is suspicious, and the prosecution has not provided a satisfactory explanation for how the accused came into possession of it.”

The Court also found issues with the seizure and handling of the evidence, which further weakened the case against the appellants.

5. Benefit of Doubt

The Court concluded that the appellants were entitled to the benefit of the doubt:

“In a case where two views are possible, the benefit of the doubt must go to the accused.”

The Court found that the circumstantial evidence presented was not strong enough to rule out the possibility of the appellants’ innocence, and therefore they must be acquitted.

Conclusion

The Supreme Court’s judgment underscores the crucial legal principle that circumstantial evidence must be strong and conclusive in criminal cases. It also highlights the importance of corroborating an extra-judicial confession with other solid evidence to make it admissible in court. In this case, the prosecution failed to provide a coherent and compelling chain of circumstantial evidence to convict the appellants. As a result, the appellants were acquitted, and the Court ruled in favor of the benefit of doubt.

This case serves as an important reminder of the high burden of proof required to convict an individual in criminal cases, especially when relying on circumstantial evidence.

Petitioner Name: Devi Lal & Another.
Respondent Name: State of Rajasthan.
Judgment By: Justice Ranjan Gogoi, Justice K.M. Joseph, Justice Ajay Rastogi.
Place Of Incident: Rajasthan.
Judgment Date: 08-01-2019.

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