Murder and Conspiracy in Rural Uttar Pradesh: Ramji Singh & Ors. vs State of Uttar Pradesh

The present case concerns an appeal filed by the accused persons, Ramji Singh & Ors., against the judgment of the Allahabad High Court, which convicted them for the murder of Sarman Singh, based on the allegations of criminal conspiracy and abetment to murder. The case arose from a dispute between the accused and the deceased over land ownership and electoral rivalries. The main issue at hand was the credibility of the eyewitness testimonies and the application of medical and ballistic evidence to support the prosecution’s case.

Key Facts of the Case:

• Sarman Singh, the deceased, had a conflict with Lakhan Singh, one of the accused, over a plot of land that Sarman Singh had started cultivating. The two had a heated argument over the land on 17th June 1982, when Lakhan Singh allegedly threatened Sarman Singh with death if he did not stop working on the disputed plot.
• Later that day, Sarman Singh was murdered in broad daylight by a group of armed individuals, including Ramji Singh (A-2), Krishna Autar (A-3), Laxman Singh (A-4), Lala Ram (A-5), and Virendra Singh (A-6), outside the house of Dasharath Singh, where the deceased had gone to collect the price for bullocks.
• The prosecution argued that the crime was a result of conspiracy among the accused, based on their earlier enmity with the deceased and the fact that the accused were all armed and engaged in a coordinated attack on the deceased.
• The Trial Court had acquitted all the accused, citing contradictions in eyewitness testimony, absence of corroborating material evidence, and failure of the prosecution to prove the case beyond reasonable doubt. The State filed an appeal in the High Court, which convicted the accused, setting aside the Trial Court’s judgment.

Petitioner and Respondent Arguments:

Petitioner (Ramji Singh & Ors.): The petitioners contended that the Trial Court had rightly acquitted them, as the medical and ballistic evidence did not support the version provided by the eyewitnesses. The defense argued that the two eyewitnesses, Babu Ram (PW-1) and Nand Kishore (PW-2), were related to the deceased and had motives to falsely implicate the accused. The petitioners also raised concerns over the delay in filing the FIR and the alleged fabrication of the report.

Respondent (State of Uttar Pradesh): The respondent argued that the High Court had correctly convicted the accused, as the testimonies of the eyewitnesses were reliable and corroborated by medical and ballistic evidence. The prosecution emphasized that the accused were involved in a coordinated attack, and their actions were premeditated. The respondent also pointed out that the delay in filing the FIR was not fatal to the prosecution’s case, as it had been adequately explained.

Important Judge Arguments:

Justice Mohan M. Shantanagoudar: Justice Shantanagoudar noted that while there were minor contradictions in the statements of the eyewitnesses, the core of their testimony remained intact. He observed that the medical evidence, particularly the nature of the injuries and the number of exit wounds, corroborated the prosecution’s version. The Court also emphasized that the ballistic evidence, although not conclusive regarding the exact firearms used, supported the assertion that the accused had fired at the deceased. The Judge further discussed how the appellant’s reliance on the site plan was misplaced, as directions and positions in a site plan could not be taken as absolutely conclusive.

Justice Deepak Gupta: Justice Gupta concurred with the findings of Justice Shantanagoudar, stressing the importance of the eyewitness testimony and its consistency with the events described in the FIR. The Judge also noted the aggressive nature of the crime, where multiple firearms were used, and the immediate threats made by the accused, which indicated a clear intent to kill the deceased. Justice Gupta further emphasized that the presence of the accused at the scene and the actions of each individual were integral to understanding the conspiracy behind the murder.

Legal Provisions Discussed:

• Section 302 (Punishment for Murder) of the Indian Penal Code (IPC): This section deals with the punishment for murder, which is applicable in cases where a person is killed by deliberate and premeditated actions. The accused were charged under this provision based on the circumstantial evidence and eyewitness testimony.
• Section 149 (Unlawful Assembly) of the IPC: This section was invoked to charge the accused with forming an unlawful assembly, as all the accused participated in the attack on Sarman Singh.
• Section 120B (Criminal Conspiracy) of the IPC: The charge under this section was based on the premise that the accused had conspired to murder the deceased, as they had planned the attack and carried out their actions with the intent to kill him.
• Section 324 (Voluntarily Causing Hurt by Dangerous Weapons) of the IPC: This provision was discussed in relation to the injuries caused by the use of axes and firearms, which were part of the assault on the deceased.

Final Judgment:

The Supreme Court dismissed the appeal, upholding the conviction of the accused. The Court emphasized that the medical and ballistic evidence corroborated the eyewitness testimonies, and the presence of the accused at the scene was sufficient to establish their involvement in the crime. The Court also observed that the defense arguments regarding the lack of ballistic evidence and contradictions in the eyewitness testimony were not strong enough to discredit the prosecution’s case. The petitioners were sentenced to life imprisonment for their role in the murder and conspiracy.

Conclusion:

This judgment reaffirms the importance of eyewitness testimony in criminal cases, particularly when supported by medical and ballistic evidence. The decision highlights the necessity of examining the totality of the evidence in murder cases, including the behavior of the accused and their actions leading up to the crime. The Court also emphasized the role of circumstantial evidence in convicting individuals involved in criminal conspiracies.

Petitioner Name: Ramji Singh & Ors..
Respondent Name: State of Uttar Pradesh.
Judgment By: Justice Mohan M. Shantanagoudar, Justice Deepak Gupta.
Place Of Incident: Uttar Pradesh.
Judgment Date: 11-12-2019.

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