Supreme Court Acquits Two Accused in Madhya Pradesh Murder Case After Nearly Two Decades

The Supreme Court of India, in its judgment dated December 7, 2022, in the case of Ramcharan (Dead) & Anr. vs. State of Madhya Pradesh, overturned the convictions of two accused persons in a murder case from 2002. The Court ruled that their convictions could not be sustained due to serious doubts regarding witness testimonies and discrepancies in evidence.

Background of the Case

The case involved the brutal assault and murder of Laxminarayan in Madhya Pradesh. According to the prosecution, the incident occurred around midnight when the complainant, Jagannath (P.W.1), his wife Kamlabai (P.W.8), their son Laxminarayan (the deceased), and other family members were sleeping outside their home near a tube-well in their field.

It was alleged that nine accused individuals arrived at the scene and started assaulting Jagannath. When Kamlabai tried to intervene, she was also attacked. Laxminarayan, who attempted to protect his parents, was chased by the accused and beaten severely. He sustained fatal injuries and died while being transported to the police station.

Trial Court and High Court Rulings

The Trial Court found all nine accused guilty under Section 302 read with Section 149 of the Indian Penal Code (IPC) and sentenced them to life imprisonment. Additionally, some accused were convicted under Sections 325 and 148 IPC for assaulting Jagannath and Kamlabai.

On appeal, the Madhya Pradesh High Court acquitted five accused and upheld the conviction of four, including the two appellants in the Supreme Court case. Accused No.4, Prem Singh, passed away during the appeal proceedings.

Arguments Presented

Petitioners’ (Accused) Arguments

The appellants, represented by their counsel, argued:

Their conviction was based solely on the testimonies of P.W.1 Jagannath and P.W.8 Kamlabai, while the evidence of other injured witnesses (P.W.10 Suganbai and P.W.11 Sharmilabai) had been disbelieved by the High Court.
There were material omissions and contradictions in the statements of P.W.1 and P.W.8, making their testimonies unreliable.
P.W.1 and P.W.8 made omnibus statements implicating all accused without differentiation, yet the High Court acquitted five of them while convicting the others.
The dying declaration of Jagannath, recorded by the Executive Magistrate, did not name five of the accused, including the two appellants.
The prosecution failed to establish beyond reasonable doubt that the appellants played any specific role in the crime.

Respondents’ (State of Madhya Pradesh) Arguments

The State of Madhya Pradesh, represented by its counsel, countered:

The testimonies of P.W.1 and P.W.8 were consistent and supported by medical evidence.
The appellants actively participated in the assault, and their presence at the scene was undisputed.
The minor inconsistencies in witness statements did not undermine the core of the prosecution’s case.
The lower courts had carefully examined the evidence and reached a fair conclusion regarding the appellants’ guilt.

Supreme Court’s Observations

The Supreme Court carefully analyzed the evidence and noted several inconsistencies and contradictions:

“The High Court disbelieved the testimony of P.W.10 and P.W.11, who were injured eyewitnesses, yet relied solely on P.W.1 and P.W.8 without corroboration.”
“P.W.1 Jagannath’s statement to the Executive Magistrate did not name accused Nos.3 and 9 (the appellants), creating doubt regarding their involvement.”
“P.W.8 Kamlabai admitted that she and P.W.1 were lying injured and unable to move for nearly an hour, casting doubt on their ability to witness the entire incident.”
“There were contradictions between the accounts of P.W.1 and P.W.8 regarding the weapons used in the attack.”
“The High Court acquitted five accused despite P.W.1 and P.W.8 assigning the same role to all accused. On the ground of parity, the appellants should also have been acquitted.”

Judgment and Ruling

The Supreme Court ruled as follows:

The conviction of the appellants under Section 302 read with Section 149 IPC was set aside.
The appellants were acquitted of all charges.
The appellants, who had been on bail, were discharged from all legal obligations, and their bail bonds were canceled.
The appeal against accused No.1, Ramcharan, was abated due to his death.

Implications of the Judgment

The Supreme Court’s ruling has significant implications for criminal law and fair trial principles in India:

Equal Treatment Under Law: The Court emphasized that when multiple accused are assigned the same role, selective conviction cannot be justified without strong evidence.
Importance of Reliable Witnesses: The ruling underscores the need for corroborated and consistent witness testimonies in serious criminal cases.
Scrutiny of Eyewitness Accounts: The judgment highlights the importance of critically examining statements from injured eyewitnesses who may have limited visibility of the crime.
Reinforcement of Legal Standards: The decision reinforces that courts must ensure that convictions are based on strong, credible evidence beyond reasonable doubt.

Conclusion

The Supreme Court’s decision in Ramcharan (Dead) & Anr. vs. State of Madhya Pradesh serves as a landmark ruling in ensuring fair trials and upholding the principle that no individual should be convicted based on uncorroborated and unreliable witness testimonies. By acquitting the two appellants, the Court has reaffirmed the necessity of proving guilt beyond reasonable doubt, setting a precedent for future criminal trials in India.

Petitioner Name: Ramcharan (Dead) & Anr..
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice Sanjay Kishan Kaul, Justice Abhay S. Oka.
Place Of Incident: Madhya Pradesh.
Judgment Date: 07-12-2022.

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