Supreme Court Convicts Accused in Acid Attack Murder Case After High Court Acquittal

The case of Suresh Chandra Jana vs. The State of West Bengal & Ors. is a significant ruling by the Supreme Court of India concerning the brutal acid attack and murder of a woman who had previously filed a rape case against one of the accused. The trial court sentenced the primary accused, Purnendu Kumar Patra, to death, but the Calcutta High Court acquitted him, citing procedural lapses and delays. The Supreme Court, however, overturned this acquittal, convicting him for murder and sentencing him to life imprisonment.

This judgment underscores the importance of fair trials, victim protection, and the role of appellate courts in ensuring justice in cases involving crimes against women.

Background of the Case

The deceased woman had lodged a complaint against the primary accused, Purnendu Kumar Patra, alleging rape on April 28, 1997. When no action was taken, she formally filed a First Information Report (FIR) on September 26, 1997. Her case was under trial when, on the night of October 26-27, 1998, two men, including Patra, attacked her with acid at her home in Contai, West Bengal.

The victim sustained severe burn injuries but managed to reach the hospital. Despite her critical condition, the police failed to record a dying declaration. After 26 days of suffering, she succumbed to her injuries on November 23, 1998. The trial court found Patra guilty of murder and sentenced him to death, while his co-accused, Rabin Jana, was sentenced to life imprisonment. However, the Calcutta High Court overturned the convictions, citing delays and inconsistencies in the prosecution’s case.

Key Legal Issues

• Whether the delayed filing of the FIR weakened the prosecution’s case.
• Whether the failure to record a dying declaration affected the credibility of the victim’s statements.
• Whether the High Court erred in acquitting the accused despite strong circumstantial evidence.
• Whether the Supreme Court should reinstate the trial court’s findings.

Arguments by the Petitioner (Brother of the Deceased and State of West Bengal)

The petitioner, represented by legal counsel, argued that:

• The victim’s complaint was valid and consistent, and the High Court wrongly disregarded it.
• The delay in the FIR was due to the victim’s hospitalization and lack of immediate support.
• There was strong motive for the crime since the accused wanted to silence the rape case witness.
• The victim’s complaint should have been treated as a dying declaration since she died due to acid attack injuries.
• The High Court’s reasoning was flawed, and the trial court’s findings should be upheld.

Arguments by the Respondent (Accused – Purnendu Kumar Patra & Rabin Jana)

The respondent countered with the following arguments:

• The FIR was delayed by 23 days, raising doubts about its authenticity.
• No formal dying declaration was recorded, making the prosecution’s case weak.
• The hospital failed to inform the police immediately, affecting the chain of events.
• The trial court did not properly follow procedural safeguards in recording the accused’s statements.
• The High Court was correct in acquitting the accused due to lack of direct evidence.

Supreme Court’s Judgment

The Supreme Court, in a judgment delivered by Justice N. V. Ramana and Justice Prafulla C. Pant, overturned the High Court’s acquittal and reinstated the murder conviction of Purnendu Kumar Patra.

1. Delayed FIR Was Justified

The Court ruled that the delay in filing the FIR was explained by the victim’s circumstances:

“The victim was in the hospital for 26 days, with no immediate family support, making it impossible for her to report the crime earlier.”

2. Victim’s Complaint Considered as Dying Declaration

The Supreme Court held that the victim’s written complaint should be treated as a dying declaration:

“Her statement, recorded before her death, narrates the entire incident and identifies the accused. The absence of a formal dying declaration does not render her statement invalid.”

3. Motive Was Strongly Established

The Court noted that Patra had a clear motive:

“The accused had previously raped the victim and sought revenge for her complaint by attacking her with acid. This establishes strong motive and premeditation.”

4. High Court’s Acquittal Was Flawed

The Supreme Court criticized the High Court’s approach:

“The High Court relied excessively on procedural lapses without appreciating the overwhelming circumstantial evidence proving the accused’s guilt.”

5. Sentence Modified from Death to Life Imprisonment

While the trial court sentenced Patra to death, the Supreme Court reduced this to life imprisonment:

“Considering the lack of prior criminal record and the mitigating circumstances, life imprisonment with a fine of Rs. 10,000 is appropriate.”

Key Takeaways from the Judgment

• Dying declarations do not always need formal recording: Statements made by victims before death can be treated as valid evidence.
• FIR delays must be viewed contextually: Courts must consider the circumstances that lead to reporting delays, especially in cases involving vulnerable victims.
• Motive strengthens circumstantial evidence: When there is clear intent, procedural lapses should not overshadow strong incriminating evidence.
• Courts must ensure justice for acid attack victims: The judgment reinforces legal protection for victims of gender-based violence.

Impact of the Judgment

This ruling has significant implications for criminal law and victim rights in India:

• Encourages fair treatment of evidence in cases with vulnerable victims.
• Strengthens judicial scrutiny of High Court acquittals that ignore circumstantial evidence.
• Reinforces the importance of motive in proving criminal intent.

Conclusion

The Supreme Court’s ruling in Suresh Chandra Jana vs. The State of West Bengal ensures justice for the deceased victim by convicting the primary accused, despite procedural flaws in the case. The judgment highlights the need for courts to prioritize substantive justice over technicalities, especially in cases of acid attacks and gender-based violence.

This decision serves as a precedent for future cases where victim statements play a crucial role, reaffirming the judiciary’s role in upholding justice even in the face of investigative lapses.

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