Appeal on Conviction Under IPC: Case of Indrapal Singh & Ors. vs. State of U.P.

This case concerns the appeals of three appellants, Indrapal Singh, Ram Pal Singh, and Surender Pal Singh, who were convicted under section 302 of the Indian Penal Code (IPC) for the murders of Atar Singh, Shivpal Singh, and Keshbhan Singh. The appellants challenge the decision of the Allahabad High Court, which had dismissed their appeals and upheld the life imprisonment sentences. This judgment delves into the circumstances of the crime, the trial proceedings, the evidence presented, and the final verdict in this tragic case of triple homicide.

Background of the Case:

The crime took place on October 22, 1995, in the village of Jalaun, Uttar Pradesh. According to the complainant, Yashwant Singh, the victims—his brothers Atar Singh, and his two nephews Keshbhan Singh and Shivpal Singh—were engaged in irrigating their land when the four accused, led by Raj Bahadur Singh, attacked them. The attackers were armed with firearms, and it was alleged that Raj Bahadur Singh had incited the others to kill the victims. Inder Pal Singh, one of the accused, fired a rifle at Atar Singh and Shivpal Singh, leading to their immediate deaths. Ram Pal Singh fired at Keshbhan Singh, who also fell dead on the spot. The attack was allegedly driven by personal and electoral enmity between the families involved.

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Petitioner’s Arguments:

The appellants’ counsel raised several points during the appeal. They first argued that the post-mortem reports (Exhibits Ka-2, Ka-12, and Ka-22) did not mention the FIR number, which created a procedural inconsistency. Additionally, they claimed that there was no FIR registered before the post-mortem was conducted. The defense further suggested that there were discrepancies in the testimonies of the prosecution’s key witnesses, particularly in the statements of PW1 (the complainant) and PW2 (another eyewitness), both of whom allegedly made improvements in their testimonies during the trial. The defense claimed these inconsistencies weakened the prosecution’s case and sought to have the conviction overturned, arguing that the evidence did not establish guilt beyond a reasonable doubt.

Respondent’s Arguments:

The prosecution, represented by the State, maintained that the conviction was justified based on the consistent testimonies of the key witnesses and the evidence presented. They emphasized that the FIR, although filed after the post-mortem, correctly detailed the sequence of events and that the testimonies of PW1 and PW2 were reliable. The prosecution also highlighted the strong evidence of the defendants being armed and the clear motive driven by longstanding electoral and property disputes. Furthermore, they stressed that there was no inconsistency in the statements made by the complainant and the eyewitnesses, and thus the charges under Section 302 read with Section 34 of the IPC were validly sustained.

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Court’s Analysis:

The Supreme Court, upon hearing both sides, took into consideration the evidence on record, including the depositions of the key eyewitnesses, the autopsy reports, and the FIR. The Court noted that despite the defense’s contention regarding the FIR’s timing, the details provided in the complaint and the post-mortem reports were consistent and corroborated the prosecution’s version of events. The Court further emphasized that the testimonies of PW1 and PW2 were coherent and consistent with the factual sequence presented in the FIR. The Court also reviewed the nature of the injuries sustained by the victims, as detailed in the autopsy reports, which corroborated the charges of murder.

Key Verbal Arguments by the Court:

In its analysis, the Court addressed the issue of the FIR timing and found that although the FIR was registered after the post-mortem, the content of the FIR was detailed and aligned with the facts provided in the complaint. The Court emphasized the importance of consistency in the testimonies of PW1 and PW2 and noted that their depositions had withstood the test of cross-examination without significant contradictions. The Court also noted the defense’s attempt to argue that there was a lack of direct involvement by one of the accused, Surender Pal Singh. However, the Court found that the overall conduct of the accused, including arriving together at the scene armed and executing the crime as a coordinated act, pointed to a common intention, justifying the application of Section 34 of the IPC (common intention).

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Conclusion:

The Supreme Court upheld the conviction of the appellants, dismissing their appeals. The Court found that the evidence was sufficient to prove the accused’s guilt beyond a reasonable doubt and that the lower courts had correctly applied the law in convicting the appellants under Section 302 read with Section 34 of the IPC. The Court emphasized that the presence of a common intention among the accused was clearly established, as they arrived together armed and committed the crime in concert. The Court further upheld the life imprisonment sentences and noted that the procedural issues raised by the defense did not diminish the overall validity of the conviction.

Petitioner Name: Indrapal Singh and Others.
Respondent Name: State of U.P..
Judgment By: Justice L. Nageswara Rao, Justice B.R. Gavai, Justice B.V. Nagarathna.
Place Of Incident: Jalaun, Uttar Pradesh.
Judgment Date: 21-09-2021.

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