Supreme Court Partially Overturns Life Sentences in Jharkhand Double Murder Case

The Supreme Court of India, in the case of Mihir Gope & Anr. vs. The State of Jharkhand, reviewed the conviction and life imprisonment of the appellants in a double murder case. The case revolved around a land dispute that led to the deaths of Anil Mahto and Jatu Mahto, with the appellants, Mihir Gope and Prabhat Gope, originally convicted under Sections 302, 307, 325, and 341 read with Section 34 of the Indian Penal Code, 1860. The Supreme Court found inconsistencies in the evidence against the appellants and reduced their conviction from murder to voluntarily causing hurt under Section 324 IPC.

Background of the Case

On 20th August 2005, a violent altercation took place in Obra Mouza, Jharkhand, over a land dispute. The dispute was primarily between Manohar Gope’s family (which included the appellants) and the family of the deceased victims. The prosecution alleged that the appellants, along with others, attacked the victims using iron rods, axes, and other weapons, leading to the deaths of Anil and Jatu Mahto and injuries to several others.

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The case was based on an FIR registered at Pindrajora Police Station, Bokaro, on the same date, following the statement of Kasi Ram Mahto, an injured eyewitness. The appellants were convicted by the Additional Sessions Judge, Fast Track Court-IV, Bokaro, and sentenced to life imprisonment. Their conviction was upheld by the High Court of Jharkhand on 10th October 2018, leading them to approach the Supreme Court.

Petitioner’s Arguments

• The appellants argued that there were inconsistencies in the eyewitness testimonies regarding their role in the attack.
• The medical evidence suggested that the injuries on the deceased victims could have been caused by accidental falls or by blunt objects rather than sharp weapons like an axe.
• There was no clear evidence proving common intention under Section 34 IPC, which was used to hold them liable for murder.
• The defense presented witnesses who claimed that the injuries resulted from falling roof tiles rather than deliberate assault.

Respondent’s Arguments

• The prosecution maintained that multiple eyewitnesses had identified the appellants as active participants in the attack.
• Medical evidence confirmed that the victims suffered severe head injuries, leading to their deaths, supporting the prosecution’s case.
• The land dispute provided a clear motive for the attack.
• The consistency in the testimonies of several eyewitnesses established the appellants’ role beyond a reasonable doubt.

Supreme Court’s Observations

The Supreme Court closely examined the evidence and found significant discrepancies in the prosecution’s case:

“The depositions of the prosecution witnesses are not uniform on the aspect of the role of these two appellants in assaulting Anil and Jatu. There is apparent inconsistency in the eyewitness account in describing the assaults by these two appellants.”

The Court noted that while multiple eyewitnesses had implicated Mihir and Prabhat, their testimonies contained contradictions regarding the nature and number of blows inflicted. Furthermore, the medical evidence indicated only one or two injuries on each victim’s head, whereas the prosecution claimed multiple blows by different individuals.

Read also: https://judgmentlibrary.com/supreme-court-reduces-sentences-in-attempted-murder-case-murali-rajavelu-vs-state/

Final Judgment

• The Supreme Court ruled that the prosecution failed to establish beyond a reasonable doubt that Mihir and Prabhat had inflicted the fatal blows.
• Conviction under Section 302 IPC (murder) was set aside.
• The Court convicted the appellants under Section 324 IPC (voluntarily causing hurt by dangerous weapons) and sentenced them to three years of rigorous imprisonment.
• The Court noted that if the appellants had already served their three-year sentence, they should be released immediately unless required in other cases.

Conclusion

The ruling highlights the importance of precise and corroborative evidence in criminal trials, particularly in cases involving multiple accused. The Supreme Court’s decision to downgrade the conviction from murder to voluntarily causing hurt reflects its commitment to ensuring justice is served based on clear and consistent evidence. This case serves as a precedent for how courts should evaluate inconsistencies in witness testimonies and medical reports in serious criminal cases.

Petitioner Name: Mihir Gope & Prabhat Gope.
Respondent Name: State of Jharkhand.
Judgment By: Justice N.V. Ramana, Justice Surya Kant, Justice Aniruddha Bose.
Place Of Incident: Obra Mouza, Jharkhand.
Judgment Date: 08-01-2021.

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