Murder Conviction Overturned: Supreme Court Acquits Woman in Assam Death Case

In a crucial ruling, the Supreme Court of India overturned the conviction of Reena Hazarika, who was earlier sentenced to life imprisonment for allegedly murdering her husband. The case, titled Reena Hazarika vs. State of Assam, centered around circumstantial evidence, discrepancies in the investigation, and the failure of the prosecution to establish an unbroken chain of evidence. The judgment highlights the importance of a fair trial and the necessity of proving guilt beyond a reasonable doubt in cases relying solely on circumstantial evidence.

Background of the Case

The case arose from an incident on the night of May 10-11, 2013, when the deceased, Reena Hazarika’s husband, was found with multiple injuries in their rented home. He succumbed to his injuries shortly thereafter. The prosecution alleged that the appellant had assaulted the deceased, leading to his death.

The prosecution’s case was based on circumstantial evidence, including the last-seen theory and the alleged unnatural conduct of the accused. Witnesses claimed to have heard noises from the couple’s home, but no one directly witnessed the crime. The trial court convicted Reena Hazarika under Section 302 of the Indian Penal Code (IPC) and sentenced her to life imprisonment with a fine of Rs. 1,000.

Post-Mortem Findings and Medical Evidence

Dr. Ritu Raj Chaliha, the prosecution’s medical expert, identified multiple chop wounds on the deceased, including injuries to the cheek, occipital region, forearm, wrist, temporal region, and scapula. The deceased also had fractures on both sides of the temporal bone. The injuries were determined to be caused by a moderately heavy sharp-cutting weapon and were homicidal in nature.

Arguments by the Appellant

Reena Hazarika’s defense counsel argued that the prosecution failed to establish an unbroken chain of circumstances pointing exclusively to her guilt. The primary points raised by the defense included:

• The alleged murder weapon, a betel nut-cutting knife, was incapable of causing the chop wounds described in the post-mortem report.
• The forensic expert was never shown the weapon to confirm whether it could have inflicted such injuries.
• The prosecution relied on the last-seen theory without corroborating evidence, ignoring the possibility that others may have been involved.
• The unnatural conduct of the accused, such as not crying after her husband’s death, was wrongly used as evidence against her.

Prosecution’s Stand

The State of Assam argued that:

• The appellant was last seen with the deceased in their home at night, making her the prime suspect.
• The accused failed to provide a satisfactory explanation for her husband’s death.
• The police recovered the alleged murder weapon and the blood-soaked clothes of the deceased.
• The accused’s failure to show remorse or emotion after the death was an indication of her involvement.

Supreme Court’s Analysis and Judgment

The Supreme Court, in its judgment delivered by Justices R.F. Nariman and Navin Sinha, emphasized that mere suspicion or last-seen circumstances cannot be the basis for conviction in the absence of direct evidence. The Court ruled:

“In a case of circumstantial evidence, the prosecution is required to establish the continuity in the links of the chain of circumstances, so as to lead to the only and inescapable conclusion of the accused being the assailant, inconsistent or incompatible with the possibility of any other hypothesis compatible with the innocence of the accused.”

The Court found several gaps in the prosecution’s case:

• The prosecution failed to explain how a betel nut knife could cause severe chop wounds.
• The multiple injuries suggested that more than one person may have been involved, which the prosecution failed to consider.
• The police failed to send the blood-stained clothes for forensic examination, which could have provided crucial evidence.
• The accused’s lack of emotional reaction was not a sufficient ground to establish guilt.

Regarding the appellant’s defense under Section 313 of the Criminal Procedure Code (CrPC), the Court ruled that her explanation was neither considered nor evaluated by the lower courts. The Court stated:

“Section 313, CrPC confers a valuable right upon an accused to establish his innocence and can well be considered beyond a statutory right as a constitutional right to a fair trial under Article 21 of the Constitution.”

Since the prosecution failed to prove the case beyond a reasonable doubt, the Supreme Court ruled that the accused was entitled to acquittal.

Impact of the Judgment

• The ruling reinforces the principle that circumstantial evidence must form an unbroken chain leading solely to the accused’s guilt.
• It highlights the role of forensic examination in criminal trials and the necessity of corroborating medical evidence with the alleged murder weapon.
• The judgment serves as a precedent for ensuring that courts adequately consider the defense under Section 313 CrPC.
• It upholds the principle that an accused person should not be convicted based on suspicion or social perceptions of behavior.

Following the Supreme Court’s ruling, Reena Hazarika was ordered to be released immediately unless she was wanted in any other case.

Petitioner Name: Reena Hazarika.
Respondent Name: State of Assam.
Judgment By: Justice R.F. Nariman, Justice Navin Sinha.
Place Of Incident: Assam.
Judgment Date: 31-10-2018.

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