Murder Conviction and Death Sentence Commuted: The Case of Manoj Suryavanshi

The case of Manoj Suryavanshi vs. State of Chhattisgarh is a significant ruling on criminal jurisprudence, particularly concerning circumstantial evidence and the imposition of the death penalty. This case highlights the complexities of proving guilt in the absence of direct evidence and the principles guiding the rarest of rare doctrine in awarding capital punishment.

Background of the Case

On February 11, 2011, three minor children—Vijay (8 years old), Ajay (6 years old), and Kumari Sakshi (4 years old)—left for school in Darripara, Chhattisgarh. After the school concluded at 11:30 AM, they were seen walking home but never arrived. Their father, Shivlal, after searching for them in the vicinity, reported them missing at the Raipur police station.

During the investigation, an eyewitness, Ashok Patel (P.W.8), claimed to have seen the children with the accused, Manoj Suryavanshi, near the school. Allegedly, the accused had a motive for revenge as his wife had eloped with Shivlal’s brother. It was suggested that to retaliate, he kidnapped and murdered the three children.

Charges and Trial Proceedings

The police lodged an FIR against Suryavanshi under Sections 363 and 364 IPC, which was later upgraded to include Section 302 IPC when the bodies of the children were found buried in a field following Suryavanshi’s confession. The forensic report confirmed that the deaths were caused by strangulation, categorizing them as homicidal.

The trial court convicted Suryavanshi based on circumstantial evidence and sentenced him to death. His appeal to the Chhattisgarh High Court was dismissed, confirming both his conviction and the death penalty.

Petitioner’s Arguments

The petitioner, Manoj Suryavanshi, contended that:

• The case was based entirely on circumstantial evidence with no eyewitness to the crime.
• The prosecution failed to establish an unbroken chain of events proving his guilt beyond reasonable doubt.
• The last seen evidence presented through P.W.1 and P.W.8 was inconsistent and unreliable.
• The mobile phone call records presented as evidence were inadmissible due to the lack of certification under Section 65B of the Indian Evidence Act.
• The alleged confession made to P.W.13 (Ashok Kumar Madhukar) was extra-judicial and inadmissible under Section 26 of the Evidence Act.
• There was no proof that the location where the bodies were found was exclusively within the knowledge of the accused.
• The accused had no prior criminal record and could be rehabilitated.
• The trial court imposed the death sentence on the same day as the conviction, violating his rights under Section 235(2) CrPC.

Respondent’s Arguments

The State of Chhattisgarh, represented by the prosecution, argued that:

• The circumstantial evidence was sufficient to complete the chain of events leading to Suryavanshi’s guilt.
• The accused had a clear motive for revenge against Shivlal.
• The accused was last seen with the children before they were found dead.
• The location of the bodies was revealed by the accused himself.
• The call records placed the accused near the crime scene at the relevant time.
• The crime was brutal, involving the deliberate killing of three innocent children, justifying the death sentence under the rarest of rare doctrine.

Supreme Court’s Observations

The Supreme Court analyzed whether the circumstantial evidence provided a complete chain leading to the accused’s guilt. The key findings were:

• The accused was last seen with the victims, as testified by multiple witnesses.
• The accused’s mobile location corresponded to the area near the crime scene.
• The bodies were found at the location disclosed by the accused.
• The accused had a strong motive for revenge.
• Medical evidence confirmed homicidal strangulation.

However, the Court also noted mitigating factors:

• The accused was emotionally disturbed due to his wife’s elopement.
• He had no previous criminal history.
• He was 28 years old at the time of the crime, indicating the potential for rehabilitation.
• He belonged to a poor family and had dependents.

Final Judgment

While upholding the conviction under Sections 302 and 364 IPC, the Supreme Court ruled that the case did not meet the threshold of the rarest of rare cases warranting the death penalty. It commuted the sentence to life imprisonment without remission for 25 years.

Impact of the Judgment

This ruling reaffirmed the importance of:

• Strict scrutiny in death penalty cases.
• The necessity of a complete chain of circumstantial evidence.
• The consideration of mitigating factors in sentencing.

By commuting the death sentence, the Supreme Court reinforced that capital punishment should be reserved for the most heinous crimes where rehabilitation is deemed impossible.

Petitioner Name: Manoj Suryavanshi.
Respondent Name: State of Chhattisgarh.
Judgment By: Justice Uday Umesh Lalit, Justice Indira Banerjee, Justice M.R. Shah.
Place Of Incident: Chhattisgarh.
Judgment Date: 05-03-2020.

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