Murder Conviction Upheld: Supreme Court Rejects Appeal in Family Dispute Case

The case of K. Ravichandra & Ors. vs. State of Karnataka revolves around a violent altercation stemming from a family dispute that resulted in the death of one person and injuries to several others. The Supreme Court had to decide whether the Karnataka High Court was justified in overturning the acquittal granted by the trial court and convicting the accused under Section 304 (II) IPC.

Background of the Case

The case originated from a personal dispute in 1996. The first accused, K. Ravichandra, had sent a Deepavali greeting card to PW-16, expressing his love for her. PW-16 showed the card to her father (PW-1), who was angered by the message. Along with PW-7, he confronted the first accused at a local canteen owned by Lingaraju.

During this confrontation, a heated argument broke out, and the accused, wielding clubs, attacked PW-1, PW-3, and PW-17. The deceased, Ramu, also suffered multiple injuries, including head trauma, and succumbed to his injuries.

Trial Court’s Verdict

• The Trial Court acquitted all the accused, ruling that the prosecution had failed to establish motive and intent.
• The court noted that the prosecution had not adequately explained the injuries sustained by the accused.
• The testimonies of key witnesses, including PW-1, were inconsistent and did not conclusively prove the guilt of the accused.

High Court’s Judgment

• The Karnataka High Court overturned the acquittal and convicted all the accused under Section 304 (II) IPC, along with other charges.
• The High Court sentenced the accused to three years of imprisonment, considering the severity of the attack.

The appellants then approached the Supreme Court.

Arguments by the Petitioner (K. Ravichandra & Ors.)

• The defense argued that the trial court had correctly acquitted the accused based on inconsistencies in the prosecution’s case.
• The defense contended that the prosecution failed to explain the injuries sustained by the accused during the altercation.
• They asserted that the confrontation was initiated by the complainant party, making them the aggressors.
• The accused had acted in self-defense, and their actions did not amount to culpable homicide.

Arguments by the Respondent (State of Karnataka)

• The prosecution maintained that the attack was deliberate and carried out using weapons.
• PW-1, PW-3, and PW-18, all injured witnesses, provided consistent statements identifying the accused as the assailants.
• Medical reports confirmed that the injuries sustained by the complainant party were severe and could not have resulted from a mere scuffle.
• The High Court was justified in overturning the acquittal because the trial court had ignored critical evidence.

Supreme Court’s Observations

The Supreme Court carefully examined the case and made the following key observations:

• Consistency of prosecution witnesses: The Court ruled that the testimonies of PW-1, PW-3, and PW-18 were consistent and corroborated by medical evidence.
• Failure to explain the injuries of the accused was not fatal: The Court clarified that the prosecution is not always required to explain the injuries sustained by the accused unless they are grievous.
• The complainant party was unarmed: The Court found that the complainant party had approached the accused for a panchayat (settlement), and there was no justification for the accused to attack them with clubs.
• The trial court’s decision suffered from perversity: The Supreme Court held that the trial court had ignored critical evidence and had wrongly acquitted the accused.

Key Judgment Excerpts

The Supreme Court ruled:

“The appreciation of evidence by the trial court suffered from perversity. The High Court, being the Appellate Court, rightly reversed the order of acquittal and convicted the appellants under Section 304 (II) IPC and other offenses for the death of deceased Ramu.”

Regarding the sentence, the Court remarked:

“The High Court, in our view, has shown leniency to the appellants by sentencing them to undergo imprisonment only for a period of three years. We are not inclined to interfere with the impugned order.”

Final Judgment

• The Supreme Court dismissed the appeal and upheld the High Court’s conviction under Section 304 (II) IPC.
• The Court ruled that the three-year sentence was appropriate given the circumstances.
• The accused were directed to surrender within four weeks to serve the remainder of their sentences.

Conclusion

This judgment reaffirms the principle that appellate courts have the authority to overturn acquittals if the trial court’s decision is found to be perverse or ignores critical evidence. The Supreme Court’s ruling highlights the importance of properly evaluating witness testimonies and medical evidence in cases of violent altercations. The case serves as a precedent for addressing family disputes that escalate into serious criminal offenses.

Petitioner Name: K. Ravichandra & Ors..
Respondent Name: State of Karnataka.
Judgment By: Justice R. Banumathi, Justice Indira Banerjee.
Place Of Incident: Karnataka.
Judgment Date: 06-09-2018.

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