Murder Conviction Overturned: Supreme Court Acquits Accused Due to Lack of Evidence

The Supreme Court of India, in Sudhakar @ Sudharasan v. State Represented by the Inspector of Police, set aside the conviction of an accused charged under Section 302 of the Indian Penal Code (IPC). The case revolved around allegations that the accused murdered his grandmother for money, but the Court found the prosecution’s case riddled with inconsistencies and unreliable witness testimonies.

Background of the Case

The case originated in Trichy, Tamil Nadu, where the accused, Sudhakar @ Sudharasan, was charged with murdering his grandmother, Mariyayee, by strangulation on January 17, 2013. The prosecution claimed that the accused, a habitual drunkard, frequently quarreled with the deceased over money and had a history of demanding financial assistance from her.

The prosecution alleged that on the evening of the incident, the accused strangled his grandmother and stole her money bag. The key eyewitness was Jayaraj (PW1), the son-in-law of the deceased, who claimed to have witnessed the accused committing the crime.

Legal Proceedings

• The trial court convicted the accused under Section 302 IPC and sentenced him to life imprisonment along with a fine of Rs. 1,000.
• The Madras High Court, in its judgment dated January 23, 2015, upheld the conviction and dismissed the appeal.
• The accused then filed an appeal before the Supreme Court.

Legal Issues Before the Supreme Court

• Whether the prosecution proved the case beyond a reasonable doubt.
• Whether the testimony of interested witnesses could be solely relied upon.
• Whether the defense of alibi raised by the accused was improperly ignored.

Arguments of the Parties

Petitioner’s (Sudhakar @ Sudharasan’s) Arguments

• The prosecution relied on testimonies of interested witnesses (PW1 and PW5), who had a property dispute with the accused.
• PW1 and PW5 gave contradictory statements, reducing their credibility.
• Independent witnesses (PW2, PW3, and PW4) turned hostile and did not support the prosecution’s version.
• The postmortem report indicated chest injuries inconsistent with strangulation.
• The accused had an alibi, as he was picked up from his mother-in-law’s house and not near the crime scene.

Respondent’s (State’s) Arguments

• The accused had a history of demanding money from the deceased and had a motive for murder.
• PW1, the prime eyewitness, saw the accused strangling the deceased.
• The money bag recovered from the accused proved his involvement.
• The inconsistencies in the witness statements were minor and did not affect the overall case.

Supreme Court’s Analysis and Judgment

The Supreme Court bench, comprising Justice N.V. Ramana and Justice S. Abdul Nazeer, examined the case critically and identified multiple flaws in the prosecution’s evidence.

1. Witness Credibility and Contradictions

The Court noted that the prosecution’s case was primarily based on the testimony of PW1 and PW5, who were related to the deceased and had an ongoing property dispute with the accused. The Court ruled:

“The evidence of an interested witness does not suffer from any infirmity as such, but it must be scrutinized with care. In this case, the contradictions and exaggerations in the testimonies create serious doubts about their reliability.”

2. Failure to Prove Motive

The Court held that while the prosecution alleged that the accused frequently quarreled with the deceased for money, no independent evidence supported this claim. It observed:

“There is no concrete proof to establish that the accused had a motive to commit the murder on the particular day.”

3. Inconsistencies in Medical Evidence

The postmortem report indicated injuries inconsistent with strangulation, suggesting that the deceased may have suffered a fall. The Court noted:

“The presence of fractured ribs and sternum casts doubt on the prosecution’s version that the deceased was strangulated.”

4. Hostile Independent Witnesses

The Court highlighted that independent witnesses (PW2, PW3, and PW4) did not support the prosecution’s version. This significantly weakened the case.

5. Defense of Alibi

The Court found that the accused’s alibi was improperly dismissed by the lower courts. The accused had presented a witness who testified that he was at another location at the time of the crime.

Final Judgment

The Supreme Court ruled in favor of the accused and issued the following directives:

• The conviction and sentence imposed by the trial court and affirmed by the High Court were set aside.
• The accused was ordered to be released immediately, unless required in any other case.
• The case was declared a miscarriage of justice due to unreliable evidence.

Impact of the Judgment

This ruling has significant implications for criminal law in India:

• Emphasis on Independent Evidence: Courts must ensure that convictions are not solely based on testimonies of interested witnesses.
• Stronger Scrutiny of Medical Reports: Forensic evidence should align with the prosecution’s claims.
• Protection Against False Implication: The judgment reinforces safeguards against wrongful convictions based on personal enmity.

Conclusion

The Supreme Court’s ruling in Sudhakar @ Sudharasan v. State Represented by the Inspector of Police is a landmark judgment emphasizing fair trial principles. By setting aside the conviction due to unreliable evidence, the Court reaffirmed the importance of proving guilt beyond reasonable doubt.

Petitioner Name: Sudhakar @ Sudharasan
Respondent Name: State Represented by the Inspector of Police, Srirangam Police Station, Trichy, Tamil Nadu
Judgment By: Justice N.V. Ramana, Justice S. Abdul Nazeer
Place Of Incident: Trichy, Tamil Nadu
Judgment Date: 12-03-2018

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