Supreme Court Acquits Dharambir in 1998 Haryana Murder Case Citing Unreliable Evidence
The Supreme Court of India has delivered a landmark judgment in Dharambir @ Dharma vs. State of Haryana, acquitting the accused in a 1998 murder case due to inconsistencies in witness testimonies and unreliable prosecution evidence. The ruling, which set aside the conviction and life sentence imposed by the Sessions Court and upheld by the Punjab and Haryana High Court, underscores the importance of ensuring due process in criminal trials.
Background of the Case
The prosecution alleged that on June 5, 1998, at approximately 11:30 AM, the accused, Dharambir @ Dharma, fatally stabbed Karambir at Prabhat Cinema, Bhiwani. The alleged motive was suspicion that Karambir was having an illicit relationship with the accused’s wife.
The case was built primarily on the testimony of Krishan Kumar (PW-5), the victim’s brother, who filed the FIR at 1:30 PM. Additional witnesses, Ravinder (PW-6) and Mahender (PW-7), were also presented as eyewitnesses. However, as the trial progressed, critical inconsistencies in the prosecution’s case began to emerge.
Legal Proceedings
Trial Court Conviction
The Sessions Judge, Bhiwani, convicted Dharambir on May 3, 1999, under Section 302 IPC (Murder) and sentenced him to life imprisonment with a fine of INR 500.
High Court Confirmation
The Punjab and Haryana High Court upheld the conviction on April 21, 2008, rejecting the defense’s contention that the evidence against the accused was unreliable.
Supreme Court Appeal
After exhausting his appeals in lower courts, Dharambir approached the Supreme Court, arguing that the prosecution had failed to prove its case beyond a reasonable doubt.
Arguments by the Appellant (Dharambir @ Dharma)
- The testimony of Krishan Kumar (PW-5), the key witness, was inconsistent and contradictory.
- There was an unexplained delay in filing the FIR, which raised concerns about the authenticity of the prosecution’s case.
- Two prosecution witnesses, Ravinder (PW-6) and Mahender (PW-7), turned hostile during the trial and denied seeing the accused commit the crime.
- The alleged extra-judicial confession before Ram Kumar (PW-8) was unreliable and lacked corroboration.
- The prosecution failed to establish that the knife recovered from the scene belonged to the accused.
Arguments by the Respondent (State of Haryana)
- The prosecution’s case was based on direct eyewitness testimony from Krishan Kumar (PW-5).
- The accused had a clear motive, as he suspected the deceased of having an affair with his wife.
- The weapon recovered from the crime scene was consistent with the murder weapon described in the post-mortem report.
- The extra-judicial confession provided independent corroboration of the accused’s involvement.
Supreme Court’s Judgment
The Supreme Court ruled in favor of the appellant, setting aside the conviction and acquitting Dharambir.
1. Witness Testimony Was Unreliable
- Krishan Kumar’s (PW-5) testimony contained significant inconsistencies.
- Two prosecution witnesses (PW-6 and PW-7) turned hostile, weakening the prosecution’s case.
- The alleged confession before Ram Kumar (PW-8) was contradicted by Piare Lal (DW-1), the defense witness.
2. Delay in Filing the FIR
- The FIR was lodged two hours after the incident, which raised suspicions of possible fabrication.
- The delay was unexplained, adding to the doubts surrounding the prosecution’s version of events.
3. Lack of Corroborative Evidence
- No independent witnesses confirmed Dharambir’s presence at the scene.
- The prosecution failed to establish that the knife used in the crime belonged to the accused.
4. Weak Motive
- The alleged motive of an illicit relationship was based on suspicion, not direct evidence.
- The accused had no prior altercations with the deceased.
5. Final Orders
- The Supreme Court set aside the conviction and life sentence.
- The appellant was acquitted and did not need to surrender.
- All pending applications were disposed of.
Legal Implications of the Judgment
This ruling reinforces several important legal principles:
- Presumption of Innocence: Accused persons are innocent until proven guilty beyond a reasonable doubt.
- Unreliable Witnesses: Courts must scrutinize inconsistencies in witness statements.
- Burden of Proof: The prosecution must establish guilt beyond a reasonable doubt.
- Judicial Oversight: Higher courts have a duty to overturn wrongful convictions.
Conclusion
The Supreme Court’s ruling in Dharambir @ Dharma vs. State of Haryana reaffirms the fundamental principles of criminal jurisprudence. The acquittal serves as a crucial reminder of the importance of fair trials, procedural safeguards, and the necessity of reliable evidence in securing convictions. By overturning the lower courts’ rulings, the judgment ensures that wrongful convictions are corrected, and justice is served.
Petitioner Name: Dharambir @ Dharma.Respondent Name: State of Haryana.Judgment By: Justice B.R. Gavai, Justice Sandeep Mehta.Place Of Incident: Bhiwani, Haryana, India.Judgment Date: 16-04-2024.
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