Murder Conviction Overturned: Supreme Court Acquits Two Accused Due to Lack of Evidence
The Supreme Court of India recently ruled on an appeal involving the murder conviction of two individuals, Hari Singh and another, who were found guilty under Section 302 of the Indian Penal Code (IPC) for allegedly attacking and killing a man named Shyam. The Court overturned the conviction due to inconsistencies in witness statements, procedural lapses in the investigation, and lack of conclusive evidence linking the accused to the crime.
Background of the Case
The case originated from an FIR filed by Shyam, the victim, alleging that he was attacked on October 17, 1997, by three individuals—Rupa, Hari ‘the Tempowala,’ and the son of Nathu. The altercation took place near Ashok Talkies, Ujjain, where the accused allegedly surrounded and assaulted Shyam with knives, causing severe injuries to his back and waist.
Shyam was taken to a hospital, where he succumbed to his injuries within hours. Initially, the case was registered under Sections 341, 294, 323, 506, and 307 read with Section 34 IPC. However, after Shyam’s death, Section 302 IPC was added. Despite the prosecution presenting multiple witnesses and medical evidence, the Supreme Court found serious discrepancies in the case.
Arguments of the Appellants (Hari Singh and Another)
The defense counsel raised the following key arguments:
- There were contradictions in the statements of key witnesses, including the injured eyewitness, Ramchander (PW-12).
- The prosecution failed to establish a clear link between the accused and the injuries sustained by the victim.
- Shyam’s dying declaration, recorded under Section 161 Cr.P.C., was unreliable due to his critical medical condition.
- There was no medical evidence to confirm that the deceased was in a fit mental state to make a dying declaration.
- The identification of the accused in the FIR was vague, using generic terms such as ‘son of Nathu’ and ‘the Tempowala.’
Arguments of the Respondent (State of Madhya Pradesh)
The prosecution countered with the following arguments:
- The FIR itself was a dying declaration and should be considered strong evidence.
- The medical report confirmed that Shyam had suffered multiple stab wounds, indicating a deliberate attack.
- The investigating officer’s testimony corroborated the events leading to the victim’s death.
- The accused had a motive, as there was a financial dispute between them and the deceased.
Supreme Court’s Analysis
1. Reliability of the Dying Declaration
The Supreme Court questioned the authenticity of the dying declaration. The bed head ticket (medical record) indicated that Shyam was in a critical state with unrecordable blood pressure. The Court observed:
“A dying declaration must be free from doubt and recorded under circumstances that ensure its voluntariness and reliability. In this case, no medical certification was obtained regarding the victim’s mental fitness before recording his statement.”
2. Contradictions in Witness Statements
The Court noted inconsistencies in the testimony of Ramchander (PW-12), who initially claimed to have witnessed the attack but later stated that it was dark and he could not identify the attackers. Furthermore, the victim’s son was not examined, and the daughter, a minor, did not support the prosecution’s case.
3. Delay in FIR Registration
The Court found discrepancies in the timeline of the FIR registration. While the incident allegedly occurred at 10 PM, the FIR was lodged at 11:35 PM, despite the police station being only a kilometer away from the crime scene.
4. Identification Issues
The Supreme Court criticized the prosecution for failing to provide specific details about the accused. The judgment stated:
“It was the prosecution’s duty to establish the identity of the accused beyond doubt. The failure to produce any concrete identification evidence creates reasonable doubt about their involvement.”
Final Judgment
The Supreme Court ruled in favor of the appellants, setting aside their conviction. The judgment concluded:
“There is reasonable doubt regarding the accused’s identity and involvement. The benefit of doubt must go to the accused, as the prosecution has failed to establish guilt beyond a reasonable doubt.”
The Court ordered the release of the appellants and discharged their bail bonds.
Implications of the Judgment
This ruling underscores the importance of procedural integrity in criminal cases. Key takeaways include:
- A dying declaration must be corroborated by medical certification and recorded in proper circumstances.
- Identification of accused persons must be precise and backed by solid evidence.
- Inconsistencies in witness statements can weaken the prosecution’s case.
- Delays in filing FIRs must be justified with reasonable explanations.
- The benefit of doubt principle must be applied when the prosecution’s evidence is inconclusive.
The Supreme Court’s decision highlights the necessity of upholding fair trial principles and ensuring that no individual is convicted based on weak or insufficient evidence.
Petitioner Name: Hari Singh & Another.Respondent Name: State of Madhya Pradesh.Judgment By: Justice Deepak Gupta, Justice Aniruddha Bose.Place Of Incident: Ujjain, Madhya Pradesh.Judgment Date: 05-09-2019.
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