Supreme Court Upholds Conviction in Karnataka Murder Case Under IPC Section 302
The Supreme Court of India delivered a critical ruling in Rajendra @ Rajappa & Ors. v. State of Karnataka, upholding the conviction of the accused under Section 302 read with Section 149 of the Indian Penal Code (IPC). The case involved the brutal murder of a man in Karnataka due to a longstanding dispute between family members.
Background of the Case
The incident took place on February 2, 2003, when the complainant, Sheshamma, was returning home with her husband and brother-in-law after working as a daily laborer. Near a government hostel, the accused—who were her father, uncles, and cousins—attacked her husband with sharp weapons, leading to his death.
The accused were initially acquitted by the Fast Track Court-IV, Gulbarga, in 2005. However, the Karnataka High Court reversed this acquittal and convicted Rajendra @ Rajappa and four others under Sections 143, 147, 148, 324, 326, and 302 read with 149 IPC. The accused then appealed to the Supreme Court.
Read also: https://judgmentlibrary.com/supreme-court-modifies-sentencing-in-karnataka-kidnapping-case/
Petitioner’s Arguments (Accused/Appellants)
The accused contended:
- The trial court had rightly acquitted them, considering contradictions in the prosecution’s case.
- The testimony of the prosecution witnesses, including the deceased’s wife, was biased as they were close relatives.
- The medical evidence was inconsistent with the witness statements.
- The High Court erred in reversing an acquittal without substantial evidence.
- Even if guilty, the case should be considered under Section 304-II IPC instead of Section 302 IPC.
Respondent’s Arguments (State of Karnataka)
The State argued:
- The High Court correctly found the trial court’s judgment to be perverse and unsupported by evidence.
- The prosecution had presented eyewitness testimony that was consistent and reliable.
- The medical and forensic evidence supported the cause of death and injuries inflicted by the accused.
- The accused acted with a common object to murder the deceased, making them liable under Section 149 IPC.
Supreme Court’s Observations
The bench comprising Justices Sanjay Kishan Kaul and R. Subhash Reddy made the following observations:
1. Credibility of Witnesses
“The trial court disbelieved the testimony of the wife (PW-1) and other eyewitnesses merely because they were related to the deceased. This approach was erroneous, as related witnesses are not necessarily unreliable.”
The Court noted that the wife’s testimony was consistent with medical reports and injury descriptions.
2. Motive for the Crime
“The attack was premeditated, arising from a family dispute over tapping toddy trees. The accused had repeatedly warned the deceased against coming near their houses.”
The Court found motive established through witness testimonies.
3. Common Object and IPC Section 149
“All accused shared a common object to kill the deceased. Their coordinated attack with lethal weapons leaves no doubt about their intent.”
The Court ruled that all accused were liable under Section 302 read with 149 IPC.
4. Reversing Acquittal
“The High Court was justified in reversing the trial court’s acquittal, as the findings were perverse and ignored crucial evidence.”
The Supreme Court held that the High Court correctly re-evaluated the evidence.
Supreme Court’s Verdict
The Supreme Court dismissed the appeal and upheld the Karnataka High Court’s conviction of the accused under Section 302/149 IPC.
Conclusion
This ruling reinforces that acquittals based on perverse findings can be overturned if supported by substantial evidence. It also underscores that related witnesses’ testimonies cannot be disregarded merely due to their relationship with the victim.
Petitioner Name: Rajendra @ Rajappa & Ors..Respondent Name: State of Karnataka.Judgment By: Justice Sanjay Kishan Kaul, Justice R. Subhash Reddy.Place Of Incident: Gulbarga, Karnataka.Judgment Date: 26-03-2021.
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