Murder Conviction Upheld: Supreme Court Relies on Witness Testimony in Chhattisgarh Case

The case of Laxminath vs. State of Chhattisgarh revolves around a brutal murder that took place in 1997. The appellant, Laxminath, was convicted under Section 302 of the Indian Penal Code (IPC) for murdering his nephew, Kursan, over a land dispute. The Supreme Court, in its judgment on September 5, 2019, upheld the life imprisonment sentence imposed by the Trial Court and confirmed by the High Court.

Background of the Case

On December 12, 1997, an argument erupted between the accused, Laxminath, and his nephew, Kursan, regarding a plot of land. The dispute intensified when Kursan opposed the construction of a house by the accused on the disputed land.

According to the prosecution, on the morning of the incident, Laxminath, armed with an axe, entered the house of the deceased and inflicted three severe blows on the side of his face, leading to his immediate death.

The First Information Report (FIR) was filed by PW-1, the father of the deceased and cousin of the accused. He stated that he was in the field when he heard his wife and daughter-in-law crying out that his son had been killed by the accused.

Legal Issues and Arguments

Arguments by the Prosecution:

• The deceased’s mother (PW-2) and sister-in-law (PW-3) were present at the house and testified that the accused entered with an axe and later emerged from the room with blood on the weapon.
• The axe used for the crime was recovered from the accused.
• The medical report confirmed that the injuries were consistent with axe blows.

Arguments by the Defense:

• There were inconsistencies in witness statements, particularly between PW-2 and PW-3 regarding the sequence of events.
• The accused was falsely implicated due to a long-standing family dispute.
• The forensic examination of the axe was not conducted, creating doubt about its use in the crime.

Supreme Court’s Observations

The Supreme Court analyzed the testimonies of key witnesses. It found that although PW-2 initially stated she saw the accused committing the crime, she later corrected herself, stating that she saw him leaving the room with the axe. Similarly, PW-3 corroborated this version.

The Court noted:

“The Trial Court rightly held that these two witnesses were not eye-witnesses but they were witnesses of facts immediately after the occurrence. They had seen the accused entering the room armed with an axe and leaving the room armed with an axe.”

The Court rejected the defense’s contention that minor inconsistencies weakened the case:

“These contradictions are not sufficient to discredit the testimony of the witnesses on material issues.”

Regarding the failure to conduct forensic tests on the axe, the Court ruled:

“Even otherwise, on the statements of PW-1, 2, and 3 alone, we are of the considered opinion that prosecution has proved its case beyond reasonable doubt.”

Key Rulings and Conclusion

The Supreme Court dismissed the appeal and upheld the life imprisonment sentence, ruling that:

• The accused was last seen entering the house with an axe and leaving with blood on the weapon.
• The statements of the deceased’s mother and sister-in-law were consistent and reliable.
• The absence of forensic examination did not weaken the prosecution’s case.
• The appellant’s claims of false implication were not supported by evidence.

This judgment highlights the importance of circumstantial evidence and the testimony of last-seen witnesses in securing a conviction in murder cases.

Petitioner Name: Laxminath.
Respondent Name: State of Chhattisgarh.
Judgment By: Justice Deepak Gupta, Justice Aniruddha Bose.
Place Of Incident: Chhattisgarh.
Judgment Date: 05-09-2019.

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