Supreme Court Restores Life Imprisonment in Uttar Pradesh Triple Murder Case
The Supreme Court of India, in the case of Sadhu Saran Singh vs. State of U.P. & Others, reinstated the life sentences of multiple accused in a case involving the brutal murder of three individuals over a land dispute. The Court overturned the Allahabad High Court’s acquittal and emphasized the importance of eyewitness testimony and forensic evidence in securing convictions.
This ruling highlights the principle that appellate courts should not interfere with well-reasoned trial court judgments unless there are compelling reasons.
Background of the Case
The case pertains to a violent altercation in Village Kanso, District Mau, Uttar Pradesh, on October 4, 1994, when the accused Ramashraya Singh, Satyendra Singh, Brijendra Singh, and others attacked Sheo Kumar, Avdhesh, and Yogendra, the three sons of the informant Bhola Singh.
The trial court convicted the accused under Sections 302, 307, 147, 148, 149, and 504 IPC, sentencing some to life imprisonment and others to death. However, the High Court acquitted all accused, leading to an appeal in the Supreme Court by the informant’s brother.
Petitioner’s (Sadhu Saran Singh) Arguments
- The High Court erroneously rejected credible eyewitness testimony.
- Forensic evidence, including bloodstains at the crime scene, corroborated the prosecution’s case.
- The acquittal was based on minor contradictions in testimony, which should not override strong evidence.
- The High Court ignored threats made to key witnesses, including the abduction of Ganga Singh, an injured witness.
Respondent’s (Accused’s) Arguments
- The prosecution’s case had inconsistencies, including conflicting medical and eyewitness reports.
- The presence of semi-digested food in the victims’ stomachs suggested a different time of death.
- The investigating officer was biased in favor of the complainants.
- Some accused had alibis proving they were not at the crime scene.
Supreme Court’s Ruling
The Supreme Court, in a judgment delivered by Justices Dipak Misra and N.V. Ramana, overturned the High Court’s acquittal and reinstated the convictions and life sentences.
1. High Court Erred in Disregarding Eyewitness Testimony
The Court emphasized the credibility of PW-1 Bhola Singh and PW-2 Baijnath Singh, ruling that their presence at the crime scene was undeniable.
“The High Court committed a manifest and grave error in analyzing the evidence of PW-1 and PW-2 and acquitted the accused without proper application of mind.”
2. Forensic Evidence Corroborated the Prosecution’s Case
Bloodstains at the crime scene matched the victims, proving that the incident occurred as stated by the prosecution.
3. Delay in FIR Not Sufficient to Discredit the Case
The Supreme Court dismissed the claim that a delayed FIR weakened the case, noting that the complaint was filed at 9:15 AM, shortly after the incident.
4. Failure to Explain Presence of Accused
The accused failed to provide convincing explanations for their whereabouts during the crime.
5. Acquittal Based on Minor Inconsistencies was Unjustified
The Court held that minor discrepancies in witness testimonies were insufficient to overturn the trial court’s judgment.
Final Verdict
The Supreme Court issued the following directives:
- The High Court’s acquittal was set aside.
- All accused were convicted under Section 302/149 IPC and sentenced to life imprisonment.
- Each accused was fined Rs. 10,000, with a default sentence of six months’ rigorous imprisonment.
- Convictions under Section 307/149 IPC (attempted murder) resulted in seven years’ rigorous imprisonment and a fine of Rs. 5,000.
- All sentences will run concurrently.
Conclusion
This judgment reinforces that High Court reversals of trial court convictions must be based on substantive legal grounds, not minor contradictions.
Key Takeaways:
- Eyewitness testimony remains crucial in criminal cases.
- Forensic evidence strengthens circumstantial cases.
- High Courts must provide strong reasons for overturning trial court findings.
- Delays in FIRs, if reasonably explained, do not weaken cases.
This ruling serves as a precedent in cases where acquittals are granted without sufficient reasoning, ensuring that justice is upheld for victims of violent crimes.
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Download Judgment: Sadhu Saran Singh vs State of U.P. & Othe Supreme Court of India Judgment Dated 26-02-2016-1741852845095.pdf
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