Murder Conviction in 1995 Bihar Case: Supreme Court Reverses Acquittal and Awards Life Sentence

The case of Harendra Rai vs. The State of Bihar & Ors. is a crucial ruling by the Supreme Court where an accused, previously acquitted by the trial and high courts, was convicted and sentenced to life imprisonment for murder. The case highlights the importance of fair prosecution and compensation for victims’ families.

Background of the Case

The case dates back to 1995 in Bihar, where a violent incident led to the deaths of Rajendra Rai and Daroga Rai and injuries to another victim, Smt. Devi. The prosecution alleged that respondent no.2 was responsible for the crime, but he was acquitted by the trial court and later by the high court.

The victim’s family, represented by appellant Harendra Rai, challenged the acquittal in the Supreme Court. On August 18, 2023, the Supreme Court reversed the acquittal, convicting the accused under Sections 302 and 307 of the Indian Penal Code (IPC).

Legal Issues Raised

The Supreme Court had to decide:

Whether the trial court and high court were justified in acquitting the accused.
Whether the prosecution’s failure to conduct a fair trial influenced the outcome.
The appropriate punishment for the convicted individual.
Whether compensation should be awarded to the victims’ families.

Petitioner’s Arguments (Harendra Rai)

The appellant argued:

The trial and high courts wrongly acquitted the accused despite strong evidence.
The prosecution and the state did not conduct a fair trial and instead assisted the accused.
The victims’ families suffered financially, physically, and emotionally due to the prolonged legal battle.
Since the accused had already been sentenced to life imprisonment in another murder case, he was a repeat offender who should receive the severest punishment.

Respondent’s Arguments (State of Bihar & Accused)

The respondent’s counsel contended:

The trial and high courts had rightly acquitted the accused due to lack of sufficient evidence.
The accused was already serving a life sentence in another case and should not be subjected to excessive punishment.
The prosecution’s failure to conduct a fair trial should not result in a severe sentence.

Supreme Court’s Ruling

The Supreme Court found that the prosecution had failed to present the case fairly and observed that the state had not acted in the interests of justice. However, based on the evidence and the severity of the crime, the Court overturned the acquittal and sentenced the accused.

1. Life Imprisonment Instead of the Death Penalty

The Court noted that while the crime was severe, 28 years had passed since the incident.
Given the time elapsed, the Court ruled that a death sentence would not be appropriate.
The accused was sentenced to life imprisonment under Section 302 IPC and fined Rs. 20 lakhs.

2. Additional Punishment for Attempt to Murder

For causing injuries to Smt. Devi, the accused was sentenced to 7 years of rigorous imprisonment under Section 307 IPC.
He was also fined Rs. 5 lakhs.
The sentences were ordered to run concurrently.

3. Compensation for Victims’ Families

The Court invoked Sections 357 and 357-A of the Code of Criminal Procedure (CrPC) to award compensation:

Rs. 10 lakhs each was awarded to the legal heirs of Rajendra Rai and Daroga Rai.
Rs. 5 lakhs was awarded to the injured victim, Smt. Devi, or her legal heirs.
The trial court was instructed to identify the legal heirs and distribute the compensation.

4. Compensation from the State of Bihar

Since the prosecution failed to ensure a fair trial, the Supreme Court ordered the State of Bihar to provide additional compensation:
The state must pay Rs. 10 lakhs each to the legal heirs of the two deceased.
Additionally, Rs. 5 lakhs must be paid to Smt. Devi or her heirs.

5. Recovery of Fine and Compliance

The fine must be deposited in the trial court within two months, failing which it will be recovered as arrears of land revenue.
The trial court must submit a compliance report to the Supreme Court within four months.

Impact of the Judgment

This ruling reinforces several legal principles:

Fair trials are essential: The state must conduct criminal trials with fairness and in the interest of justice.
Victims’ families deserve compensation: Courts must ensure financial relief for those affected by violent crimes.
Accountability for prosecutorial failure: If the prosecution fails in its duty, the state may be held responsible.
Severe crimes require severe penalties: Even after decades, justice must be served for serious offenses.

Conclusion

The Supreme Court’s decision in Harendra Rai vs. The State of Bihar is a landmark ruling ensuring that justice prevails despite the failures of the prosecution. By overturning the acquittal, sentencing the accused to life imprisonment, and awarding substantial compensation to the victims’ families, the Court upheld the principle that justice should not be denied due to procedural lapses. This judgment serves as a reminder that the criminal justice system must always prioritize fairness, accountability, and the rights of victims.

Petitioner Name: Harendra Rai.
Respondent Name: The State of Bihar & Ors..
Judgment By: Justice Sanjay Kishan Kaul, Justice Abhay S. Oka, Justice Vikram Nath.
Place Of Incident: Bihar.
Judgment Date: 01-09-2023.

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