Supreme Court Acquits Two Accused in Madhya Pradesh Robbery Case Due to Lack of Evidence

The Supreme Court of India recently delivered a landmark judgment in Manoj Kumar Soni & Kallu @ Habib vs. State of Madhya Pradesh, acquitting the accused of robbery and criminal conspiracy due to lack of credible evidence. The judgment, delivered by S. Ravindra Bhat and Dipankar Datta, emphasized that convictions must be based on clear, consistent, and reliable evidence rather than mere suspicion.

The case revolved around an armed robbery in Madhya Pradesh, where multiple accused individuals were convicted. However, due to inconsistencies in witness statements, procedural lapses, and unreliable disclosure statements, the Supreme Court overturned the convictions of two appellants, highlighting the fundamental principle of proving guilt beyond reasonable doubt.

Background of the Case

The case stemmed from an armed robbery that took place on April 14, 2010, in Madhya Pradesh. The complainant, a woman living alone, alleged that four armed robbers entered her house, tied her up along with her servant, and looted her gold and silver jewelry, cash, and other valuables. An FIR was lodged under Section 394 IPC, and the police arrested multiple suspects, including the two appellants in this case.

Chronology of Events

April 14, 2010: Armed robbers enter the complainant’s house and loot valuables.
May 9 & 21, 2010: Police claim to have recovered stolen jewelry from the possession of appellant Manoj Kumar Soni.
May 12, 2010: Co-accused allegedly reveals that Kallu @ Habib provided inside information about the victim.
November 28, 2019: The trial court convicts all five accused under various sections of IPC, sentencing Manoj to 3 years under Section 411 IPC and Kallu to 10 years under Section 120-B IPC.
October 12, 2022: Madhya Pradesh High Court upholds the conviction of all accused.
August 11, 2023: The Supreme Court overturns the convictions of Manoj and Kallu, citing unreliable evidence.

Petitioner’s Arguments

The appellants, represented by their legal counsel, contended:

The case against them was based purely on circumstantial evidence, without direct proof linking them to the crime.
Witness statements regarding the seizure of stolen jewelry were inconsistent, and several witnesses turned hostile.
The prosecution failed to establish the necessary elements of criminal conspiracy under Section 120-B IPC.
The disclosure statements by co-accused should not have been relied upon, as they were not corroborated by independent evidence.
The delay in recording statements and procedural lapses in conducting identification weakened the prosecution’s case.

Respondent’s Arguments

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

The stolen items were recovered from Manoj, proving his involvement in the crime.
Kallu provided insider information about the victim’s wealth, facilitating the robbery.
Witness testimonies and police investigations established the accused’s role in the conspiracy.
The High Court had already reviewed the evidence and found no grounds for acquittal.

Supreme Court’s Analysis

The Supreme Court examined multiple aspects of the case and found serious lapses in the prosecution’s case.

1. Weak Evidence Against Manoj Under Section 411 IPC

The Court found that the seizure witnesses who allegedly signed the seizure memos for the stolen jewelry had turned hostile and denied the prosecution’s claims.

“All four independent witnesses (PW-5, PW-6, PW-11, and PW-16) turned hostile, which casts serious doubts on the prosecution’s case.”

2. Failure to Prove Criminal Conspiracy Against Kallu

The Court found that the only evidence against Kallu was the statement of a co-accused, which was not corroborated by any independent proof.

“A person cannot be convicted for conspiracy under Section 120-B IPC when no other accused has been convicted under the same section.”

3. No Direct Link Between Recovered Articles and the Crime

The Court held that the prosecution failed to establish that the jewelry allegedly recovered from Manoj was the same as what was stolen from the complainant.

“A mere recovery of items, without conclusive identification, does not prove the accused’s involvement in the robbery.”

4. Procedural Lapses and Violation of Section 313 CrPC

The Court observed that the trial court had recorded Manoj’s statement under Section 313 CrPC in a casual manner, failing to give him an opportunity to explain key circumstances.

“The manner in which the trial court recorded the statement of the accused left much to be desired. The accused was not given a fair opportunity to explain the evidence against him.”

Final Verdict

The Supreme Court ruled:

The convictions of Manoj and Kallu were quashed due to lack of credible evidence.
Both accused were acquitted and ordered to be released immediately.
The ruling reaffirmed the importance of proving criminal cases beyond reasonable doubt.

This judgment serves as a strong precedent for ensuring that criminal convictions are based on credible and conclusive evidence, preventing wrongful convictions based on suspicion or procedural lapses.

Petitioner Name: Manoj Kumar Soni & Kallu @ Habib.
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice S. Ravindra Bhat, Justice Dipankar Datta.
Place Of Incident: Madhya Pradesh.
Judgment Date: 11-08-2023.

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