Murder Conviction Upheld: Supreme Court Reinforces Evidence-Based Approach in Criminal Appeals

The Supreme Court of India has upheld the conviction of Achhar Singh and Budhi Singh in a case of murder and grievous assault. The judgment, delivered on May 7, 2021, in Achhar Singh & Anr. v. State of Himachal Pradesh, reaffirms the principles governing appellate review in criminal cases and the importance of consistent, corroborated evidence.

Background of the Case

The case concerns a violent attack on February 23, 1996, in Mandi, Himachal Pradesh, where a group of villagers, led by the appellants, forcibly entered the house of the complainant and assaulted multiple family members, resulting in the death of Swari Devi and severe injuries to Beli Ram.

The key facts, as per the prosecution, are:

The complainant, Netar Singh, his wife Meera Devi, and his mother Swari Devi were socially boycotted by the villagers led by Budhi Singh.
The victims were attacked inside their house by a group of armed men, including the appellants.
Budhi Singh inflicted a fatal axe blow on Swari Devi’s head.
Achhar Singh assaulted Beli Ram with an axe, rendering him unconscious.
The complainant escaped to the roof and later reported the crime to the local Gram Pradhan and the police.

Trial Court Verdict

The Trial Court acquitted all the accused, citing inconsistencies in witness testimonies and potential false implication due to previous enmity. The judgment observed:

The prosecution witnesses exaggerated the number of injuries inflicted on the deceased.
There were contradictions between the FIR, medical reports, and witness statements.
The delay in lodging the FIR (registered at 9:30 AM the next day) raised doubts about the authenticity of the allegations.

High Court’s Reversal

The Himachal Pradesh High Court, upon appeal, reversed the acquittal of Achhar Singh and Budhi Singh while upholding the acquittal of the other accused. The High Court’s key findings included:

The FIR, despite minor inconsistencies, was consistent in implicating Budhi Singh as the perpetrator of the fatal axe blow.
Medical evidence confirmed that the deceased had one fatal head injury inflicted by a sharp-edged weapon.
Witnesses consistently stated that Achhar Singh attacked Beli Ram, corroborated by medical evidence showing incised wounds.
Delays in lodging the FIR were justified given the unavailability of transport and the rural setting.
The social boycott of the complainant’s family meant that independent witnesses were unwilling to testify.

Arguments by the Petitioners (Achhar Singh & Budhi Singh)

The appellants’ counsel raised several points:

The trial court’s acquittal was based on a possible view of the evidence and should not have been interfered with.
The prosecution witnesses exaggerated their accounts, alleging multiple axe blows when medical reports confirmed only one.
The High Court failed to give the benefit of doubt where contradictions were apparent.
Budhi Singh had no motive to commit the crime as his daughter’s wedding was ongoing at the time.
The blood trail outside the house suggested that the crime did not occur as described by the prosecution.

Arguments by the Respondent (State of Himachal Pradesh)

The State’s counsel countered:

The trial court had overlooked consistent, corroborated evidence against the appellants.
The exaggerated testimonies did not negate the core facts establishing the appellants’ guilt.
The High Court acted within its power to reverse the acquittal where the trial court’s reasoning was found to be perverse.
Eyewitnesses, despite some contradictions, were consistent in attributing the fatal blow to Budhi Singh.
Legal principles dictate that an acquittal can be overturned where there is a failure to appreciate material evidence.

Supreme Court’s Observations

1. Principles Governing Appellate Review

The Court reiterated that appellate courts have the power to reassess evidence in an appeal against acquittal if the trial court’s judgment is perverse:

“The High Court was justified in interfering with the trial court’s judgment, which overlooked consistent evidence establishing the guilt of the appellants.”

2. Differentiating Exaggeration from Falsehood

The Court emphasized that exaggeration in witness statements does not render the entire testimony false:

“An exaggerated statement contains elements of truth, whereas a false statement is completely devoid of truth. The duty of the court is to sift the grain from the chaff.”

3. Justification for Delay in FIR

The Court held that the delay in lodging the FIR was reasonable given the circumstances:

“The complainant had to walk 24 kilometers at night to reach the police station, which explains the time gap between the incident and the FIR registration.”

4. Eyewitness Testimonies

The Court found the witness statements consistent on material aspects:

“The presence of exaggeration does not negate the core facts—that Budhi Singh inflicted a fatal axe blow and Achhar Singh grievously injured Beli Ram.”

5. No Parity with Acquitted Accused

The Court rejected the plea for parity with other acquitted co-accused:

“The allegations against Narinder Singh were uncorroborated, whereas those against Budhi Singh and Achhar Singh were supported by medical evidence.”

Final Verdict

The Supreme Court dismissed the appeals, affirming the High Court’s ruling:

“The appellants’ convictions under Sections 302 and 452 IPC (Budhi Singh) and Sections 452, 326, and 323 IPC (Achhar Singh) are upheld. They are directed to undergo the remainder of their sentences.”

Conclusion

This ruling underscores the importance of evidence-based adjudication in criminal cases. It clarifies that appellate courts can reverse acquittals where the trial court has failed to appreciate material evidence. The judgment sends a strong message against violent crimes and ensures that legal technicalities do not obstruct justice.

Petitioner Name: Achhar Singh & Budhi Singh.
Respondent Name: State of Himachal Pradesh.
Judgment By: Justice Surya Kant, Justice Aniruddha Bose.
Place Of Incident: Mandi, Himachal Pradesh.
Judgment Date: 07-05-2021.

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