Mahatma Gandhi Assassination: Supreme Court Dismisses Plea for Reinvestigation
The case of Dr. Pankaj Kumudchandra Phadnis vs. Union of India sought a reinvestigation into the assassination of Mahatma Gandhi, which occurred on January 30, 1948. The petitioner, a researcher, alleged the presence of a conspiracy beyond the known facts and questioned the validity of the earlier judicial findings. The Supreme Court had to determine whether there was any legal basis for reopening a long-concluded case.
Background of the Case
The assassination of Mahatma Gandhi led to a historic trial in which Nathuram Godse and Narayan Apte were sentenced to death, while other accused received varied sentences. The case was tried before a Special Judge in Delhi, and the Punjab High Court later upheld the convictions. The petitioner, Dr. Phadnis, filed a Public Interest Litigation (PIL) seeking a review of the case based on alleged discrepancies and new research.
Key Arguments
Petitioner’s Argument (Dr. Pankaj Kumudchandra Phadnis)
- Claimed that there was an “unseen hand” involved in Gandhi’s assassination.
- Argued that four bullets were fired instead of three, challenging the original forensic findings.
- Requested the reopening of the Kapur Commission Report (1969), which had examined the conspiracy behind Gandhi’s assassination.
- Alleged that new research justified a fresh probe into the case.
Respondent’s Argument (Union of India)
- The case was thoroughly investigated and tried in 1948-49, with conclusive judicial findings.
- No new credible evidence was presented by the petitioner that could justify reopening the case.
- The Kapur Commission’s findings had no judicial impact, as they did not overturn the criminal court’s judgment.
- Reopening a historically settled case would lead to unnecessary controversy and public disorder.
Supreme Court’s Judgment
A bench comprising Justices S.A. Bobde and L. Nageswara Rao ruled against the petitioner, making the following key observations:
1. No Legal Basis for Reinvestigation
The court emphasized that criminal cases involving convictions and executions should not be reopened decades later based on speculative research.
“We are not satisfied that new research into a long-concluded matter justifies a re-initiation of criminal investigation.”
2. No Evidence of a Fourth Bullet
The petitioner alleged that four bullets were fired, contradicting official records. However, the court found no credible evidence to support this claim. The original forensic reports, FIR, and eyewitness accounts all confirmed that three bullets struck Gandhi.
3. Eyewitness Testimonies Confirmed Godse’s Actions
The court relied on six eyewitness testimonies and forensic evidence, which confirmed that Nathuram Godse was the sole assassin and fired three bullets from his semi-automatic Beretta pistol.
4. Kapur Commission Report Not a Judicial Verdict
The petitioner sought a review of the Kapur Commission’s findings, particularly regarding Vinayak Damodar Savarkar. The court clarified that the Commission’s findings were not binding and did not overturn Savarkar’s acquittal.
“The submission that Savarkar has been held guilty for the murder of Gandhi is misplaced.”
5. No Merit in the Petition
The court rejected the plea, calling it an exercise in futility. It warned against using the judiciary to fuel historical controversies.
“This Court must at all costs be wary of such contentious issues and must not allow its jurisdiction to be invoked for such purposes.”
Conclusion
The Supreme Court’s ruling reaffirmed that historically and legally settled cases should not be reopened based on academic speculation. This judgment upholds the finality of criminal convictions and protects the legal system from unnecessary controversy.
Petitioner Name: Dr. Pankaj Kumudchandra PhadnisRespondent Name: Union of IndiaJudgment By: Justice S.A. Bobde, Justice L. Nageswara RaoPlace Of Incident: New DelhiJudgment Date: 28-03-2018
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