Supreme Court Acquits Guman Singh in Murder Case Due to Unreliable Eyewitnesses

The case of Guman Singh vs. The State of Rajasthan is a significant judgment where the Supreme Court overturned a conviction under Section 302 of the Indian Penal Code (IPC) for murder and under Section 307 read with Section 34 IPC for attempted murder. The Court critically analyzed the reliability of eyewitness testimonies, forensic evidence, and procedural lapses before reaching its verdict.

Background of the Case

Guman Singh was convicted by the Trial Court for the murder of Shiv Charan and the attempted murder of Babu Singh based on an FIR (No. 464/2009) registered on August 30, 2009, at Hindaun City, District Karauli, Rajasthan. According to the prosecution, Guman Singh and his co-accused Satvir Singh and Shyam Singh fired shots at the victims while they were traveling on motorcycles near Chauve ka bandh.

The Trial Court sentenced Guman Singh to life imprisonment under Section 302 IPC with a fine of Rs. 10,000. Additionally, he was sentenced to 10 years’ rigorous imprisonment under Section 307 IPC, with a fine of Rs. 1,000. The Rajasthan High Court upheld the conviction. However, the Supreme Court, after a thorough examination, found inconsistencies in the prosecution’s case and overturned the conviction.

Key Legal Issues

Were the prosecution’s eyewitnesses reliable and credible?
Did the forensic evidence substantiate the charges?
Was the delay in recording key witness statements justified?
Did the prosecution prove its case beyond reasonable doubt?

Arguments Presented

Petitioner (Guman Singh):

The eyewitness testimonies of Tara Singh (PW-1) and Varun Singh (PW-4) were contradictory and did not align with the statements of the investigating officers.
The FIR appeared to be backdated and failed to immediately identify the accused.
The forensic report did not conclusively establish that the bullets recovered from the victim’s body were fired from the alleged murder weapon.
There was no independent corroboration of the prosecution’s claim that Guman Singh fired the fatal shot.

Respondent (State of Rajasthan):

The prosecution relied on direct eyewitness accounts from Tara Singh and Varun Singh, who both stated that they saw Guman Singh fire at the victims.
The forensic examination showed that the bullet wounds were consistent with the type of weapon allegedly recovered from Guman Singh.
The delay in recording witness statements was due to the victims’ hospitalization and fear of retaliation.
The conviction was based on substantial circumstantial and direct evidence.

Supreme Court’s Observations and Judgment

The Supreme Court closely examined the prosecution’s evidence and found several inconsistencies. The Court noted the following key issues:

1. Unreliable Eyewitnesses

The two key prosecution witnesses, Tara Singh (PW-1) and Varun Singh (PW-4), claimed to have been present at the crime scene and to have seen Guman Singh fire the fatal shot. However, their testimonies were contradicted by the investigating officer, Gulam Navi (PW-7), and the injured witness, Babu Singh (PW-3).

Babu Singh (PW-3), the sole surviving victim, did not identify Guman Singh as the shooter. Instead, he testified that he did not see who fired the shots.
Gulam Navi (PW-7), the investigating officer, stated that no eyewitnesses were present when the police arrived at the crime scene.
The first time Tara Singh and Varun Singh mentioned Guman Singh’s name was nearly three hours after the incident, raising doubts about their credibility.

2. Flaws in the FIR and Delay in Witness Statements

The FIR was lodged at 8:20 PM, nearly three hours after the incident. However, the investigating officer stated that no witnesses identified the accused until much later. The Supreme Court found this delay significant and held that such unexplained delays create doubts about the authenticity of the statements.

3. Inconclusive Forensic Evidence

The forensic report failed to establish a definitive link between the bullets recovered from the victims’ bodies and the weapon allegedly used by Guman Singh. The bullets retrieved from the deceased were not sent for ballistic examination, and the report on the bullet found in Babu Singh’s body stated that it could not be conclusively linked to the recovered weapon.

4. Acquittal of Co-Accused

Two of the co-accused, Satvir Singh and Shyam Singh, were acquitted by the High Court due to lack of evidence. The Supreme Court reasoned that if the prosecution failed to prove their involvement, there was insufficient basis to convict Guman Singh solely on weak eyewitness testimonies.

The Supreme Court ruled:

“The prosecution has failed to prove its case beyond reasonable doubt. The contradictions in witness testimonies and lack of conclusive forensic evidence cast significant doubt on the guilt of the accused.”

Accordingly, the Supreme Court set aside Guman Singh’s conviction and ordered his immediate release.

Implications of the Judgment

This ruling reinforces the principle that convictions must be based on credible and consistent evidence.
Eyewitness accounts must be corroborated by forensic evidence to ensure fairness in criminal trials.
Delays in recording witness statements must be justified by the prosecution to avoid doubts about witness credibility.
The Supreme Court emphasized that a conviction cannot be sustained merely on suspicion and that the prosecution must establish guilt beyond reasonable doubt.

Conclusion

The Supreme Court’s decision in this case underscores the importance of due process and the presumption of innocence in criminal trials. By acquitting Guman Singh, the Court reaffirmed that an accused cannot be convicted solely based on unreliable witness testimonies and inconclusive forensic evidence. This judgment serves as a significant precedent in ensuring fair trials in murder cases.

Petitioner Name: Guman Singh.
Respondent Name: State of Rajasthan.
Judgment By: Justice Indira Banerjee, Justice Sanjiv Khanna.
Place Of Incident: Karauli, Rajasthan.
Judgment Date: 24-05-2019.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: Guman Singh vs State of Rajasthan Supreme Court of India Judgment Dated 24-05-2019.pdf

Direct Downlaod Judgment: Direct downlaod this Judgment

See all petitions in Murder Cases
See all petitions in Attempt to Murder Cases
See all petitions in Judgment by Indira Banerjee
See all petitions in Judgment by Sanjiv Khanna
See all petitions in allowed
See all petitions in supreme court of India judgments May 2019
See all petitions in 2019 judgments

See all posts in Criminal Cases Category
See all allowed petitions in Criminal Cases Category
See all Dismissed petitions in Criminal Cases Category
See all partially allowed petitions in Criminal Cases Category