Supreme Court Acquits Man in Murder Case Due to Lack of Evidence

The case of Shatrughan v. The State of Chhattisgarh is a crucial ruling where the Supreme Court overturned the conviction of the appellant for murder under Section 302 of the Indian Penal Code (IPC). The Court found significant inconsistencies in the prosecution’s case, unreliable witness testimony, and a lack of conclusive forensic evidence. This judgment emphasizes the principle that conviction must be based on proof beyond a reasonable doubt, not mere suspicion.

Background of the Case

The case dates back to July 19, 2008, when the deceased, Jagat Ram, was allegedly attacked with a tabbal (a sharp-edged weapon) while he was returning home on his bicycle in Kasdol, Raipur. The prosecution claimed that the accused, Shatrughan, attacked Jagat with the tabbal, leading to his death.

The First Information Report (FIR) was lodged by Vijay Kumar (PW-1), the uncle of the deceased, on July 20, 2008, at 4:30 AM. He stated that he heard his nephew shouting, “Kaka Vijay Singh, run! Shatrughan has assaulted me with a tabbal.” Upon reaching the scene, PW-1 saw Jagat lying on the ground, bleeding from a neck wound, while the accused was allegedly fleeing on a bicycle.

The Trial Court convicted the accused under Section 302 IPC and sentenced him to life imprisonment, a ruling later upheld by the Chhattisgarh High Court. The accused then appealed to the Supreme Court, arguing that his conviction was based on circumstantial and hearsay evidence rather than concrete proof.

Key Legal Issues

Was the conviction based on substantive evidence, or was it purely circumstantial?
Did the witness testimony align with the forensic and medical evidence?
Did the prosecution prove beyond a reasonable doubt that the accused committed the crime?

Petitioner’s (Appellant’s) Arguments

The appellant, represented by his counsel, contended:

There were no direct eyewitnesses to the alleged murder.
The case was based entirely on circumstantial and hearsay evidence.
The prosecution failed to establish motive—none of the witnesses stated any enmity between the accused and the deceased.
Medical evidence contradicted the prosecution’s claims.
The FIR was registered at 4:30 AM on July 20, 2008, but the police had already arrived at the scene at 4:00 AM, raising doubts about the delay and potential fabrication.

Respondent’s (State’s) Arguments

The prosecution argued that:

The accused was seen fleeing the crime scene, indicating guilt.
Jagat had allegedly named the accused before collapsing.
The post-mortem report confirmed that the victim died from a deep neck wound caused by a sharp-edged weapon.
The accused had a history of conflicts with local villagers, including the Sarpanch, who had filed a complaint against him.

Supreme Court’s Observations

The Supreme Court examined multiple aspects of the case, finding serious inconsistencies in the prosecution’s claims.

On the Alleged Dying Declaration

The Court found inconsistencies in the claim that the deceased had named the accused before collapsing. The statement recorded in the FIR was:

“Kaka Vijay Singh, run! Shatrughan has assaulted me with a tabbal.”

However, upon reviewing witness testimonies, the Court found:

PW-1 initially claimed to have heard the deceased’s dying declaration, but later admitted that Jagat was already unconscious when he arrived at the scene.
Other witnesses (PW-3, PW-4) confirmed that Jagat was unable to speak when they reached him.
The Court ruled that the alleged statement could not be relied upon, as it was contradicted by multiple witnesses.

On Medical and Forensic Evidence

The medical report noted:

The victim had one sharp incised wound on the left side of the neck.
The weapon allegedly used was 13.5 cm long, but the wound was only 5 cm long, raising doubts about whether it was the cause of the injury.
The forensic expert (PW-6) admitted that the injury could not have been caused by the recovered weapon.
The post-mortem also confirmed that Jagat had consumed alcohol before the incident, raising the possibility that he had fallen onto a sharp object.

On Witness Testimonies

The Court noted contradictions in key witness statements:

PW-1 claimed to have seen the accused running away but changed his version in court.
PW-2, PW-3, and PW-4 did not see the accused at the crime scene.
PW-9 (a neighbor) initially said that the victim named the accused but later admitted he did not hear Jagat speak.
The Sarpanch (PW-11) denied that he had prior disputes with the accused, contradicting earlier statements.

On the Absence of Motive

The Court found that the prosecution failed to establish a motive:

All witnesses admitted that there was no enmity between the accused and the deceased.
The accused had filed a complaint against the Sarpanch for corruption, leading to speculation that he was falsely implicated.

Final Judgment

The Supreme Court ruled:

“There is no direct evidence linking the accused to the crime. The prosecution has failed to establish guilt beyond a reasonable doubt.”

The Court acquitted the accused, stating:

“The accused has been in custody for 15 years based on weak circumstantial evidence. His conviction is set aside, and he is to be released immediately.”

Implications of the Judgment

This ruling has significant implications for criminal law:

Reinforcing the Burden of Proof: Convictions must be based on direct evidence, not mere suspicion.
Scrutiny of Witness Testimonies: Courts must critically examine inconsistencies in witness statements.
Ensuring Fair Trials: Accused individuals should not be convicted without clear, corroborative evidence.

Conclusion

The Supreme Court’s decision in Shatrughan v. The State of Chhattisgarh highlights the importance of fair trials and the need for conclusive evidence in criminal cases. The judgment serves as a critical reminder that no person should be punished based on weak circumstantial evidence, and the presumption of innocence must be upheld until proven guilty beyond a reasonable doubt.

Petitioner Name: Shatrughan.
Respondent Name: The State of Chhattisgarh.
Judgment By: Justice Vikram Nath, Justice Ahsanuddin Amanullah.
Place Of Incident: Kasdol, Raipur, Chhattisgarh.
Judgment Date: 19-07-2023.

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