Appeal against acquittal in murder charge: State of Madhya Pradesh vs Amar Lal

The present case involves an appeal filed by the State of Madhya Pradesh against the acquittal of Amar Lal from the charge of murder under Section 302 of the Indian Penal Code (IPC). The High Court had upheld the acquittal, but the State contended that the evidence presented, including ocular testimonies and the nature of the assault, was sufficient to convict the respondent. The respondent’s conviction under Section 323 IPC (causing hurt) had been affirmed, but the question of murder remained in dispute.

Key Facts:

The assault on the deceased occurred on 27.03.1990 when the respondent allegedly attacked the deceased using the pointed end of a wooden plough, a tool used for tilling land.
The key eyewitnesses to the assault were PW-4 and PW-5, both of whom were family members of the deceased, and PW-5 was also injured in the incident.
The State’s case was that the nature of the injuries, which involved a sharp object (the plough), should have matched the evidence of a corresponding wound, but the defense argued that the injuries were not consistent with a sharp object. The medical opinion, given by Doctor PW-6, suggested that the injuries could only have been caused by a blunt, hard substance, leading to the acquittal.
The appellant, the State of Madhya Pradesh, argued that the High Court erred by accepting the medical opinion without considering the clear ocular evidence provided by the witnesses.

Petitioner and Respondent Arguments:

Petitioner (State of Madhya Pradesh): The State argued that the acquittal was unjust, as the ocular evidence from PW-4 and PW-5 was reliable and consistent. The assault was carried out using a wooden plough, which the State contended should have left injuries corresponding to a sharp, pointed object, contrary to the medical opinion. The State further argued that the acquittal was based on an erroneous interpretation of the medical evidence.

Respondent (Amar Lal): The respondent’s counsel, led by senior advocate Anukul Chandra Pradhan, submitted that the respondent had already served a significant period in custody, having been in detention for 14 years, 6 months, and 7 days. The defense highlighted that the respondent had already undergone 11 years and 9 months of imprisonment before the High Court’s judgment, which had affirmed his conviction under Section 323 IPC for causing hurt, and contended that the acquittal in the murder charge was justified.

Important Judge Arguments:

Justice Ashok Bhushan: Justice Bhushan observed that while the medical opinion was important, the Court must also consider the reliability and consistency of the eyewitness testimonies, particularly when they come from close family members who witnessed the incident. He agreed with the respondent’s counsel that the acquittal should not be overturned based on the medical evidence alone, especially when the respondent had already spent over a decade in custody.

Justice Navin Sinha: Justice Sinha concurred with the judgment of Justice Bhushan, noting that the appeal did not present compelling enough reasons to overturn the acquittal. He acknowledged the extended period of imprisonment already served by the respondent and found no grounds to interfere with the High Court’s decision.

Legal Provisions and Case Law:

Section 302 IPC (Murder): The appellant argued that the assault was a clear case of murder, as the injuries were caused by a sharp object (wooden plough). The respondent’s defense questioned the matching of injuries to the weapon used.
Section 323 IPC (Causing Hurt): The respondent was convicted under this section, and the High Court’s decision to affirm this conviction was not contested. The focus was on the question of murder.
Precedent: State of U.P. v. Pradip Tandon (1975): The Court referred to this case to establish the importance of corroborating medical evidence with eyewitness testimonies, especially when the medical evidence is inconclusive.

Final Judgment:

The Supreme Court dismissed the appeal, affirming the acquittal of the respondent in the murder charge under Section 302 IPC. The Court emphasized that the medical evidence, although important, did not override the eyewitness testimonies provided by PW-4 and PW-5. The Court also took into account the long period of custody already served by the respondent, which weighed heavily in the final decision.

Conclusion:

The judgment highlights the need to carefully weigh medical and ocular evidence in criminal cases, particularly in cases involving serious charges like murder. The Court’s decision to uphold the acquittal reflects the importance of preserving the principles of fairness and justice, even in cases where the State has presented strong evidence. The acquittal was seen as justified given the medical uncertainties and the length of the respondent’s imprisonment.

Petitioner Name: State of Madhya Pradesh.
Respondent Name: Amar Lal.
Judgment By: Justice Ashok Bhushan, Justice Navin Sinha.
Place Of Incident: Madhya Pradesh.
Judgment Date: 10-12-2019.

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