Featured image for Supreme Court Judgment dated 25-07-2019 in case of petitioner name Ranjit Kumar Haldar vs State of Sikkim
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Murder Conviction Upheld: Supreme Court Affirms Guilt in Sikkim Custodial Death Case

The Supreme Court of India, in its judgment dated July 25, 2019, upheld the conviction of Ranjit Kumar Haldar and Mamta Mohanta in the murder case of Netai Mohanta. The Court confirmed that the accused were responsible for concealing the deceased’s body under wooden planks in a rented house in Sikkim. This case highlights the importance of circumstantial evidence and the application of Section 106 of the Indian Evidence Act.

Background of the Case

The case originated when an FIR was lodged by Bhola Mohanta (PW-1), the brother of the deceased, on December 28, 2004. He reported that his brother, Netai Mohanta, had traveled to Rabom Power House, Lachung, with the accused, Ranjit Kumar Haldar, for carpentry work. However, he later discovered that his brother had been murdered and buried inside the house where they were staying.

The key facts of the case include:

  • The deceased was last seen with the accused at the rented house.
  • The body was found buried beneath wooden planks covered with mud and stones.
  • The accused, Mamta Mohanta (wife of the deceased), made a disclosure statement that led to the recovery of the body.
  • The postmortem confirmed that the death resulted from head injuries and strangulation.

Trial and Conviction

During the trial, multiple witnesses testified against the accused:

  • Jamyang Bhutia (PW-5), the landlord, confirmed renting two rooms to Ranjit Haldar.
  • Ravi Deb (PW-3), a fellow carpenter, identified the deceased’s body by his sweater and religious mala.
  • Doma Lepcha (PW-2), a local panchayat leader, testified that Mamta Mohanta confessed to the crime.

Based on these testimonies and forensic evidence, the trial court convicted both accused under Section 302 (murder) of the IPC. The conviction was upheld by the High Court.

Supreme Court’s Observations

The Supreme Court examined the following critical points:

  • The FIR was originally lodged in Bengali and later translated into Nepali, but the defense’s objection to the translation was deemed inconsequential.
  • The body was recovered based on Mamta Mohanta’s disclosure, strengthening the prosecution’s case.
  • The postmortem confirmed that the cause of death was head injuries and strangulation.
  • The defense argument that DNA testing was required was rejected, as the body was identified through personal belongings and witness testimonies.

The Supreme Court stated:

“The consistent evidence of prosecution witnesses establishes beyond reasonable doubt that the accused were responsible for the murder of the deceased.”

Key Arguments of the Parties

Arguments by the Petitioner (Ranjit Kumar Haldar and Mamta Mohanta):

  • The FIR was not credible due to language translation errors.
  • There was no direct evidence linking them to the murder.
  • The prosecution failed to establish motive.
  • DNA testing was not conducted to confirm the deceased’s identity.

Arguments by the Respondent (State of Sikkim):

  • The accused were the last people seen with the deceased.
  • Their rented house was locked until the police forced entry.
  • Forensic evidence corroborated that the deceased had suffered fatal injuries.
  • The disclosure statement of Mamta Mohanta led to the recovery of the body.

Final Verdict

The Supreme Court ruled in favor of the prosecution, upholding the convictions of the accused. The key takeaways from the judgment are:

  • The conviction under Section 302 IPC was confirmed.
  • The accused’s argument regarding translation discrepancies was dismissed.
  • The burden of proof under Section 106 of the Evidence Act was rightly applied, as the accused failed to explain the circumstances leading to the death.
  • The circumstantial evidence was sufficient to establish guilt.

Conclusion

This judgment reaffirms the significance of circumstantial evidence in criminal trials. It also highlights the necessity for accused persons to provide a reasonable explanation when deaths occur in their presence. The Supreme Court’s ruling ensures that justice is served while reinforcing the importance of procedural and evidentiary integrity in criminal proceedings.


Petitioner Name: Ranjit Kumar Haldar.
Respondent Name: State of Sikkim.
Judgment By: Justice L. Nageswara Rao, Justice Hemant Gupta.
Place Of Incident: Sikkim.
Judgment Date: 25-07-2019.

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