Murder Conviction Upheld: Supreme Court Rules on Eyewitness Reliability and Forensic Evidence
The Supreme Court of India, in the case of Rakesh & Another vs. State of Uttar Pradesh & Another, upheld the conviction of the appellants for the murder of Bhishampal Singh. The ruling clarifies the importance of eyewitness testimony, the role of forensic evidence, and the applicability of Section 302 read with Section 34 of the Indian Penal Code (IPC) in cases of multiple accused.
The Supreme Court dismissed the appeal against the conviction and life imprisonment sentence, stating that the presence of the accused, the sequence of events, and corroborated forensic evidence sufficiently established their guilt.
Background of the Case
The case involved a murder that took place on January 28, 2006, in Hathras, Uttar Pradesh. The appellants, Rakesh and Anish, along with another accused, Suresh, were charged with:
- Section 302 read with Section 34 (murder with common intention) of the IPC.
- Sections 4/25 of the Arms Act (illegal possession and use of weapons).
The prosecution alleged that:
- Rakesh (A1) shot the deceased, Bhishampal Singh, with a country-made pistol.
- Suresh (A2) and Anish (A3) inflicted knife injuries on the deceased.
- The attack was premeditated, as there was a longstanding enmity between the accused and the deceased.
The trial court convicted all three accused and sentenced them to life imprisonment, which was later upheld by the Allahabad High Court.
Key Legal Issues
- Whether the eyewitness testimony was credible and reliable.
- Whether forensic evidence supported the prosecution’s case.
- Whether the participation of A2 and A3, who used knives, made them liable for murder under Section 34 IPC.
- Whether contradictions in weapon descriptions affected the conviction.
Petitioners’ Arguments
The appellants contended:
- That the eyewitness (PW1 and PW2) testimonies were unreliable and contained inconsistencies.
- That PW2’s presence at the crime scene was doubtful.
- That A2 and A3 inflicted injuries after the deceased had already died from the gunshot, and thus they should not be convicted for murder.
- That there was a discrepancy in the description of the weapons used.
Respondents’ Arguments
The State of Uttar Pradesh, represented by the Additional Advocate General, countered:
- That PW1 and PW2 were reliable witnesses and had no reason to falsely implicate the accused.
- That the presence of the accused at the crime scene was established beyond doubt.
- That motive was clear, as there was a longstanding enmity between the deceased and A1.
- That forensic evidence corroborated the eyewitness testimony.
Supreme Court’s Observations and Judgment
Credibility of Eyewitnesses
The Supreme Court upheld the credibility of the eyewitnesses, stating:
“Both PW1 and PW2 were present at the time of the incident, and their testimonies corroborate each other. Minor inconsistencies do not affect the overall reliability of their statements.”
Application of Section 34 IPC
The Court held that A2 and A3 were correctly convicted under Section 302 read with Section 34, even though the gunshot caused the initial fatal injury:
“The common intention to kill was evident from the coordinated attack. The injuries caused by A2 and A3 reinforced the murderous intent, making them equally liable.”
Weapon Discrepancies
The Court rejected the argument that discrepancies regarding the knife or dagger used affected the case:
“Eyewitnesses may describe weapons differently based on perception, but their core testimony remains reliable. The medical evidence confirms the nature of the injuries.”
Ballistics Report and Gunshot Injury
The appellants argued that the ballistic report showed that the bullet did not match the gun recovered from A1. However, the Court ruled:
“Even if the recovered gun was not the murder weapon, the evidence that A1 shot the deceased remains undisputed. Eyewitness testimony and medical reports confirm the gunshot wound.”
Motive and Prior Enmity
The Supreme Court noted that the deceased was facing trial for an earlier attempt to murder A1. The Court stated:
“The longstanding enmity provides a clear motive, further strengthening the case against the accused.”
Final Ruling
The Supreme Court dismissed the appeal, affirming the convictions:
- Rakesh (A1) was held guilty of directly shooting the deceased.
- Suresh (A2) and Anish (A3) were convicted under Section 302 read with 34 IPC for acting with common intention.
- The sentence of life imprisonment for all accused was upheld.
Key Takeaways from the Judgment
- Eyewitness reliability – Minor inconsistencies do not invalidate credible testimonies.
- Common intention in murder cases – Coordinated attacks can make all participants equally liable.
- Ballistics report vs. direct evidence – Failure to match bullets to the recovered firearm does not negate a murder charge.
- Motive strengthens prosecution cases – Prior enmity supports a conviction if other evidence aligns.
Conclusion
The Supreme Court’s judgment in Rakesh vs. State of Uttar Pradesh reinforces the principle that convictions can be based on strong eyewitness accounts supported by forensic evidence. It also clarifies the application of Section 34 IPC in cases where multiple accused are involved in a single murder.
By affirming the life imprisonment sentences, the Court ensures that the gravity of the crime and the role of each accused in a coordinated attack are adequately addressed.
Petitioner Name: Rakesh & Another.Respondent Name: State of Uttar Pradesh & Another.Judgment By: Justice Dhananjaya Y. Chandrachud, Justice M.R. Shah.Place Of Incident: Hathras, Uttar Pradesh.Judgment Date: 06-07-2021.
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