Murder Conviction Overturned: Supreme Court Acquits Accused Due to Unreliable Evidence

The case of Chunthuram v. State of Chhattisgarh revolves around an appeal challenging the conviction under Section 302 IPC read with Section 34 IPC. The appellant, Chunthuram, was sentenced to life imprisonment for the alleged murder of Laxman. The Supreme Court analyzed whether the conviction was based on reliable evidence and whether the prosecution had established guilt beyond a reasonable doubt.

Background of the Case

The case originated from an incident on June 14, 2001, when Laxman was allegedly attacked with an axe and a stick while returning from Tamta Market to Pandripani Village. According to the prosecution, the accused, Chunthuram and Jagan Ram, ambushed the deceased, leading to his immediate death. The FIR was lodged by Mahtoram (PW1), the father of the deceased, stating that his grandson, Santram, had informed him about the murder. The FIR also mentioned a longstanding land dispute between the accused and the deceased.

Key Legal Issues

• Whether the prosecution presented sufficient evidence to sustain the conviction.
• Whether the testimonies of eyewitnesses were credible and consistent.
• Whether forensic evidence supported the prosecution’s case.
• Whether the defense was able to establish reasonable doubt in the prosecution’s case.

Arguments by the Petitioner

The petitioner, Chunthuram, argued:

• The prosecution failed to provide substantive forensic evidence linking him to the crime.
• The recovered weapons were never conclusively linked to the alleged murder.
• The eyewitness, Bhagat Ram (PW4), had poor eyesight and could not reliably identify the assailants.
• The land dispute cited by the prosecution had been settled two years prior to the incident, making revenge an unlikely motive.
• The conduct of Bhagat Ram (PW4) after the alleged incident was unnatural—he did not immediately report the crime or inform law enforcement.

Arguments by the Respondent

The State of Chhattisgarh countered:

• There was a history of enmity between the accused and the deceased.
• Weapons of assault were recovered at the location identified by the accused.
• The eyewitness testimony of Bhagat Ram (PW4) confirmed that Chunthuram was present at the scene.
• The evidence, though circumstantial, established the guilt of the accused beyond a reasonable doubt.

Supreme Court’s Observations

1. Unreliable Eyewitness Testimony

The Supreme Court noted that the conviction was largely based on the testimony of Bhagat Ram (PW4). However, the Court found significant inconsistencies:

“The witness admitted to having poor eyesight and could not see objects beyond two feet. Moreover, the incident took place in low visibility conditions due to cloudy weather.”

The Court also observed that Bhagat Ram (PW4) was 200 yards away from the crime scene, while another witness, Taj Khan (PW2), who was much closer, did not hear any cries for help.

2. Lack of Forensic Linkage

The Court examined the forensic evidence presented by the prosecution. It found:

• Weapons allegedly used in the attack were recovered, but no conclusive bloodstains were found on them.
• The chemical analyst report referenced by the trial court was not available in the case records, raising doubts about its existence.

The Court concluded:

“The absence of forensic confirmation weakens the prosecution’s case significantly.”

3. Procedural Lapses in Test Identification Parade

The Court analyzed the Test Identification Parade (TIP) conducted for the accused and found major flaws:

• The identification exercise was conducted in the presence of police, making it unreliable.
• Filim Sai (PW3), the key identification witness, was shown only one lungi for identification instead of the three that were reportedly presented.
• The lungi was found 150 feet away from the crime scene, contradicting the witness’s claim that it was 10–12 steps away.

The Court ruled:

“When an identification parade is conducted improperly, the results cannot be relied upon as substantive evidence.”

4. Motive and Circumstantial Evidence

The prosecution relied on a motive theory involving a past land dispute and a previous murder involving the victim. However, the Court found no immediate cause for the accused to commit the crime:

“The dispute was settled years before the incident. Without any immediate provocation, attributing motive to the accused remains speculative.”

5. Application of the Benefit of Doubt Principle

The Court reiterated the principle that if two views are possible—one pointing to guilt and the other to innocence—the view favoring the accused must be adopted. Citing previous rulings, it stated:

“Criminal law requires proof beyond a reasonable doubt. When key evidence is unreliable, a conviction cannot be sustained.”

Final Verdict

The Supreme Court allowed the appeal and acquitted the accused, ruling that:

• The prosecution failed to establish guilt beyond a reasonable doubt.
• The eyewitness testimony was unreliable.
• The forensic evidence was inconclusive.
• The identification process was flawed.
• The prosecution failed to demonstrate a credible motive.

Implications of the Judgment

This ruling reinforces several legal principles:

• Eyewitness testimonies must be scrutinized for reliability.
• Forensic evidence must conclusively link the accused to the crime.
• Test Identification Parades must be conducted without police presence to ensure credibility.
• The benefit of doubt must be given to the accused when substantial inconsistencies exist in the prosecution’s case.

The judgment highlights the need for robust evidence in criminal cases to prevent wrongful convictions.

Petitioner Name: Chunthuram.
Respondent Name: State of Chhattisgarh.
Judgment By: Justice Sanjay Kishan Kaul, Justice Krishna Murari, Justice Hrishikesh Roy.
Place Of Incident: Jashpurnagar, Chhattisgarh.
Judgment Date: 29-10-2020.

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