Murder Conviction Upheld: Supreme Court Rules on Eyewitness Testimony and Delay in FIR

The Supreme Court of India, in the case of Mallikarjun and Others vs. State of Karnataka, examined the reliability of eyewitness testimony, delay in lodging the FIR, and the credibility of medical and forensic evidence. The Court upheld the life imprisonment sentence for two of the accused while acquitting one accused due to lack of evidence.

Background of the Case

The case involved the brutal murder of Bhimraya, allegedly due to an illicit affair between the deceased and the wife of one of the accused. The crime occurred on June 14, 2002, in the village of Saidapur, Karnataka. The prosecution alleged that the accused persons entered the victim’s house, dragged him outside, and inflicted multiple stab wounds, leading to his death. The victim’s mother, Kamalamma (PW-5), was the primary eyewitness, and the case largely relied on her testimony.

The Trial Court convicted the accused under Section 302 read with Section 34 of the Indian Penal Code (IPC) and sentenced them to life imprisonment. The Karnataka High Court upheld the conviction, leading the accused to appeal before the Supreme Court.

Key Legal Issues

• Whether the delay in registering the FIR affected the credibility of the prosecution’s case.
• Whether the eyewitness testimony of PW-5 was reliable.
• Whether forensic and medical evidence corroborated the prosecution’s claims.
• Whether all accused were equally liable for the murder.

Arguments by the Appellants (Accused)

The appellants contended:

• The delay in registering the FIR and its receipt by the Magistrate raised doubts about the credibility of the prosecution’s case.
• The eyewitness testimony of PW-5 suffered from contradictions and should not be relied upon.
• The forensic evidence did not conclusively establish the presence of all accused at the crime scene.
• One of the accused (Accused No.4) was falsely implicated and should be acquitted.

Arguments by the Respondents (State of Karnataka)

The respondents countered:

• The delay in FIR registration was explained and did not affect the reliability of the prosecution’s case.
• The testimony of PW-5 was consistent and corroborated by medical evidence.
• Forensic and post-mortem reports confirmed the nature of the injuries and supported the prosecution’s version of events.
• Accused No.1 and Accused No.2 were directly responsible for the fatal injuries.

Supreme Court’s Observations

1. Delay in FIR Registration

The Court ruled that while the FIR was lodged at 1:15 PM and received by the Magistrate at 8:00 PM, the delay was not significant enough to vitiate the prosecution’s case. The Court noted:

“The delay in registration of the FIR does not, by itself, create doubt unless it is unexplained. Here, the prosecution has sufficiently explained the circumstances leading to the delay.”

2. Reliability of Eyewitness Testimony

The Court relied on the testimony of PW-5, the mother of the deceased, who had directly witnessed the incident. It stated:

“The testimony of a close relative cannot be discarded merely on the ground of relationship if it is otherwise found credible and consistent with the prosecution’s case.”

3. Medical and Forensic Evidence

The Court examined the post-mortem report, which confirmed multiple stab wounds on the deceased’s body, particularly a deep chop wound on the neck that led to excessive bleeding and immediate death. The Court ruled:

“The post-mortem findings are consistent with the injuries described by the eyewitness, and they corroborate the prosecution’s version of the attack.”

4. Conviction and Acquittal

While the Supreme Court upheld the conviction of Accused No.1 and Accused No.2, it found that Accused No.4 had not been directly involved in the attack. The Court stated:

“Benefit of doubt must be given to Accused No.4, as the prosecution failed to establish his direct role in the murder beyond reasonable doubt.”

Final Verdict

The Supreme Court ruled:

• The conviction and life sentence of Accused No.1 (Mallikarjun) and Accused No.2 (Ravi) were upheld.
• Accused No.4 (Balappa) was acquitted due to lack of conclusive evidence.
• The appeal was partly allowed, modifying the sentence only for Accused No.4.

Conclusion

This judgment reinforces the importance of eyewitness testimony in criminal trials while setting a precedent for carefully evaluating forensic evidence. The ruling also underscores that minor delays in FIR registration do not automatically invalidate a prosecution case, provided the delay is reasonably explained. The verdict ensures that justice is served while upholding the principle of ‘beyond reasonable doubt’ in criminal law.

Petitioner Name: Mallikarjun and Others.
Respondent Name: State of Karnataka.
Judgment By: Justice R. Banumathi, Justice A.S. Bopanna.
Place Of Incident: Saidapur, Karnataka.
Judgment Date: 08-08-2019.

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