Murder Conviction Reinstated: Supreme Court Upholds Life Imprisonment in Punjab Double Homicide Case
The case of Darshan Singh v. State of Punjab highlights a long legal battle involving a double murder, self-defense claims, and a plea of alibi. The Supreme Court was called upon to determine whether the acquittal of Darshan Singh by the trial court was justified or whether the High Court was right in convicting him under Section 302 of the Indian Penal Code (IPC). This case underscores the significance of eye-witness testimony, medical evidence, and the judicial scrutiny applied to self-defense and alibi pleas.
Background of the Case
The incident in question took place on February 17, 1995, in Faridkot, Punjab. The prosecution alleged that the conflict arose due to a long-standing dispute over irrigation rights between two factions. The situation had already escalated into legal proceedings under Section 107/151 of the Code of Criminal Procedure (CrPC) before the Executive Magistrate in Faridkot.
The Fatal Altercation
On the day of the incident, complainant Amrik Singh (PW-1), along with Raj Singh (PW-3), Sukhchain Singh (PW-2), and others, was attending court proceedings. The accused, including Surain Singh, Jasmail Singh, Darshan Singh (appellant), and Jhanda Singh, were also present at the court complex. A verbal altercation broke out, escalating into violence.
According to the prosecution:
- Accused Surain Singh took out a Siri Sahib (a sharp-edged weapon) and attacked Bhajan Singh, leading to a full-blown brawl.
- Accused Darshan Singh (the appellant) inflicted grievous injuries on Santa Singh, who later succumbed to his injuries.
- Two members of the complainant party, Harbans Singh and Santa Singh, died due to the injuries sustained.
- The accused party also suffered injuries, leading them to claim that they acted in self-defense.
Trial Court Proceedings
The case was committed to the Additional Sessions Judge, Faridkot, and registered as Sessions Case No. 33 of 1995. On July 7, 1995, charges were framed against the accused under various sections of the IPC, including Sections 148, 302/149, 307/149, 324/149, 218, and 201. All accused pleaded not guilty.
The trial court, after evaluating the evidence, convicted:
- Surain Singh under Section 302 IPC for the murder of Harbans Singh.
- Other accused, Jhanda Singh, Jasmail Singh, and Pal Singh, under Sections 302/34, 307/34, and 324/34 IPC.
However, Darshan Singh (the appellant) was acquitted due to insufficient evidence proving his role in the crime.
Appeal Before the High Court
The State of Punjab challenged the acquittal of Darshan Singh before the Punjab and Haryana High Court. The High Court re-evaluated the evidence and reversed the trial court’s decision. It convicted Darshan Singh under:
- Section 302 IPC (murder of Santa Singh) and sentenced him to life imprisonment.
- Section 324 IPC (voluntarily causing hurt with a dangerous weapon) for injuries to Gursewak Singh and Raj Singh.
He was sentenced to life imprisonment and fined Rs. 5,000. In default of payment, he was to undergo an additional six months of rigorous imprisonment.
Appeal Before the Supreme Court
Darshan Singh appealed against his conviction, arguing:
- The High Court erred in reversing the trial court’s acquittal.
- There was no direct evidence against him.
- He had an alibi as he was attending his duty as a Laboratory Assistant at a school.
Prosecution’s Counter-Arguments
The State contended:
- The appellant’s alibi was false.
- There were multiple injured eyewitnesses who testified against him.
- Medical evidence corroborated the presence of the accused at the scene.
Supreme Court’s Observations
1. Reliability of Eye-Witness Testimonies
The Supreme Court emphasized:
“Ocular testimony of injured witnesses cannot be discarded lightly. Once the prosecution has discharged its burden, the burden to prove that the appellant was not present lies on him.”
2. Medical and Forensic Evidence
The post-mortem report of Santa Singh revealed multiple stab wounds:
- One stab wound pierced his heart.
- Another wound penetrated his intestines.
- Three additional stab wounds were observed on his chest and back.
These injuries were consistent with eyewitness accounts of Darshan Singh attacking Santa Singh with a sharp weapon.
3. Rejection of Alibi
The appellant’s defense relied on school records showing that he was present at work. However, the Supreme Court found inconsistencies:
“The attendance register was not seized immediately after the incident. His plea of alibi is vacillating.”
Additionally, Darshan Singh had applied for casual leave on February 16, 1995, suggesting he planned to be absent on the day of the incident.
Final Judgment
The Supreme Court dismissed the appeal, upholding the High Court’s conviction. It ruled that the appellant was guilty beyond a reasonable doubt.
“After scrutinizing the entire evidence, we do not find any illegality in the appreciation of evidence or in arriving at the conclusion as to the guilt of the appellant.”
Key Takeaways
- Ocular testimony, especially from injured witnesses, carries significant evidentiary value.
- Medical reports and forensic evidence play a crucial role in corroborating witness statements.
- Self-defense and alibi claims require strong evidence to counter prosecution testimonies.
- The High Court has the power to overturn acquittals if the evidence justifies a conviction.
Conclusion
The Supreme Court’s ruling in Darshan Singh v. State of Punjab sets a precedent in evaluating alibi claims and the importance of medical evidence in murder cases. By reinstating the conviction, the court reaffirmed its stance on upholding justice based on substantive evidence rather than procedural loopholes.
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Download Judgment: Darshan Singh vs State of Punjab Supreme Court of India Judgment Dated 06-01-2016.pdf
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