Supreme Court Acquits Woman Accused in Unlawful Assembly and Murder Case

The case of Amrika Bai vs. The State of Chhattisgarh is a landmark ruling where the Supreme Court acquitted a woman accused of being part of an unlawful assembly that led to a murder. The judgment emphasized that mere presence in an unlawful assembly does not automatically make an individual guilty unless there is evidence of a shared common object.

Background of the Case

The case originated on August 12, 1989, in a village in Chhattisgarh. The deceased, Kapil, was taking his cattle for grazing when they allegedly jumped on the door of the appellant’s house. This led to an argument between Kapil and the appellant, Amrika Bai. Later that day, when Kapil returned, he questioned Amrika Bai about her earlier remarks. At this point, the prosecution alleged that she pretended to touch his feet and instead caught hold of him, facilitating his murder by co-accused individuals who were armed with weapons.

Following the incident, an FIR was lodged against 14 individuals, including Amrika Bai. The trial court convicted 10 of them, including the appellant, under:

• Section 302 read with Section 149 IPC (murder committed by an unlawful assembly)
• Section 147 IPC (rioting)

The appellant was sentenced to life imprisonment under Section 302 and one year of rigorous imprisonment under Section 147 IPC. She subsequently appealed her conviction.

High Court Decision

While the appeal was pending, some co-accused individuals were released on special reprieve, and one of the accused died. The Chhattisgarh High Court upheld the conviction of the remaining accused, including Amrika Bai.

Dissatisfied with the ruling, the appellant approached the Supreme Court, arguing that she had been wrongfully implicated based on unreliable evidence.

Legal Issues Before the Supreme Court

The key legal questions were:

• Whether the appellant’s conviction was based on credible and consistent evidence.
• Whether mere presence in an unlawful assembly was sufficient to convict her of murder.
• Whether there were inconsistencies in the prosecution’s version of events.

Arguments by the Petitioner (Amrika Bai)

• The prosecution’s witnesses were close relatives of the deceased, making their testimonies unreliable due to potential bias.
• The allegations against her were inconsistent across different witness statements.
• The prosecution failed to establish her role beyond reasonable doubt.
• The FIR was forwarded to the Magistrate four days after registration, suggesting possible manipulation of the case.

Arguments by the Respondent (State of Chhattisgarh)

• The prosecution argued that Amrika Bai actively participated in the crime by restraining the deceased while others attacked him.
• Witness testimonies corroborated that she was present and involved in the unlawful assembly.
• Her conduct before and during the incident indicated a common object to commit the offense.

Supreme Court’s Analysis and Judgment

The Supreme Court scrutinized the evidence presented and found multiple inconsistencies in the prosecution’s version. The Court noted:

• “The testimonies of prosecution witnesses are contradictory regarding the role of the appellant in the incident.”
• “While one witness claimed she merely held the deceased, another stated she actively assaulted him with a lathi.”
• “The prosecution witnesses were close relatives of the deceased, requiring their testimony to be examined with caution.”
• “The FIR was filed late, raising concerns about possible fabrication of evidence.”

The Court emphasized that mere presence in an unlawful assembly does not make a person guilty unless there is proof of a common object to commit the offense. It cited the precedent set in Dani Singh v. State of Bihar (2004), which held that an individual cannot be convicted solely for being present in an unlawful assembly.

Final Judgment

The Supreme Court ruled as follows:

• The conviction under Section 302 read with Section 149 IPC was set aside.
• The conviction under Section 147 IPC was also set aside.
• The appellant was acquitted of all charges.

Significance of the Judgment

This ruling sets important legal precedents:

• Mere presence in an unlawful assembly does not imply guilt.
• Inconsistent witness statements can weaken the prosecution’s case.
• Courts must scrutinize delayed FIRs to prevent potential misuse of legal procedures.
• Judicial caution is required when convicting based on witness testimony from close relatives of the victim.

Conclusion

The Supreme Court’s decision in Amrika Bai vs. The State of Chhattisgarh highlights the importance of due process and fair trial principles. The ruling reinforces that every accused person is entitled to the presumption of innocence until proven guilty beyond reasonable doubt. By acquitting the appellant, the Court ensured that justice was served by preventing wrongful conviction based on weak and contradictory evidence.

Petitioner Name: Amrika Bai.
Respondent Name: The State of Chhattisgarh.
Judgment By: Justice N.V. Ramana, Justice Mohan M. Shantanagoudar, Justice Indira Banerjee.
Place Of Incident: Bilaspur, Chhattisgarh.
Judgment Date: 29-03-2019.

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