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Gulzari Lal vs. State of Haryana: Supreme Court Upholds Life Imprisonment in Murder Case

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The case of Gulzari Lal vs. State of Haryana revolves around a brutal murder that took place in 1999, leading to the conviction of the appellant under Sections 302 and 323 read with Section 34 of the Indian Penal Code (IPC). The case traveled through various judicial stages, ultimately reaching the Supreme Court, which upheld the conviction and sentence of life imprisonment.

Background of the Case

The prosecution’s case was that on the intervening night of May 26-27, 1999, Maha Singh was brought to the Civil Hospital, Hisar, in an injured condition. The doctor on duty found him fit to make a statement, which was recorded by Head Constable Manphool Singh (PW-7) at around 10:00 AM on May 27, 1999. However, at that stage, no cognizable offense was registered.

Later, Maha Singh’s condition deteriorated, and he was referred to PGI Rohtak. On May 28, 1999, he was transferred back to the Government Hospital, Hisar, where he was declared dead upon arrival. Following his death, an FIR was registered under Sections 302 and 323 read with Section 34 IPC.

After investigation, the police arrested three accused, including the appellant, Gulzari Lal. Charges were framed against them on November 18, 1999, and the case proceeded to trial.

Trial Court Proceedings

The prosecution presented 14 witnesses during the trial. Key among them were:

  • Head Constable Manphool Singh (PW-7): He recorded the dying declaration of Maha Singh.
  • Dariya Singh (PW-1): An eyewitness and son of the deceased, who sustained injuries in the attack.
  • Rajinder Singh (PW-11): An independent witness who saw the appellant leaving the crime scene.

The trial court convicted Gulzari Lal under Sections 302 and 323 IPC and sentenced him to life imprisonment along with a fine of Rs. 200. In default of payment, he was required to undergo an additional one-month imprisonment.

High Court Appeal

The accused challenged the trial court’s judgment before the Punjab and Haryana High Court. The High Court upheld the trial court’s findings, emphasizing:

  • The dying declaration of the deceased was corroborated by eyewitness accounts.
  • The medical evidence supported the prosecution’s version.
  • The forensic report confirmed the presence of blood at the crime scene.

The High Court found no merit in the appeal and dismissed it.

Arguments Before the Supreme Court

The appellant approached the Supreme Court, raising several contentions:

  • No clear motive: The appellant argued that there was no enmity between him and the deceased, and hence, no motive for committing the crime.
  • Questioning the dying declaration: It was contended that the dying declaration was fabricated, as the deceased was allegedly not in a fit state to give a statement.
  • Lack of forensic evidence: The defense highlighted that no blood-stained earth was recovered from the crime scene.

Prosecution’s Counterarguments

The State argued that:

  • The dying declaration was recorded when the deceased was medically fit.
  • The evidence of eyewitnesses, especially that of Rajinder Singh (PW-11), was credible and unshattered.
  • The forensic report supported the prosecution’s case.

Supreme Court’s Judgment

The Supreme Court dismissed the appeal, affirming the conviction. Key observations included:

  • A dying declaration does not require corroboration if found to be voluntary and truthful.
  • The statements of independent witnesses, particularly Rajinder Singh (PW-11), placed the appellant at the crime scene.
  • The absence of blood-stained earth did not weaken the prosecution’s case, as corroborative evidence was available.

The Supreme Court ruled that the trial court and the High Court had correctly appreciated the evidence, and there was no ground to interfere with the conviction.

Conclusion

This judgment reinforces the principle that a dying declaration, if found credible, can be the sole basis for conviction. It also highlights the importance of eyewitness testimony and corroborative forensic evidence in securing justice.

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