Supreme Court Upholds Life Imprisonment for Murder Conviction in Punjab

The case of Baljinder Singh @ Ladoo & Others vs. State of Punjab revolves around a brutal murder that occurred in 1997 in Punjab. The Supreme Court, in its judgment dated September 25, 2024, upheld the conviction and life sentence of three accused individuals while confirming the acquittal of one co-accused. The Court rejected arguments of self-defense and false implication, affirming that the appellants acted with common intention to commit murder.

This case reaffirms legal principles surrounding Section 34 IPC (common intention) and Section 149 IPC (unlawful assembly) in criminal trials. The judgment clarifies how courts should evaluate evidence, particularly eyewitness testimonies and forensic findings.

Background of the Case

The incident took place on December 12, 1997, in a village in Punjab. The case stemmed from a minor altercation between Puran Singh @ Bhola (PW-3) and one of the accused, Baljinder Singh @ Ladoo. According to the prosecution, Baljinder Singh’s scooter accidentally hit Puran Singh, leading to a heated exchange. Puran Singh slapped Baljinder, which escalated the conflict.

Within 15 minutes of the incident, Baljinder Singh (A-1) returned with his brothers A-2 and A-3, and their father A-4. The assailants, armed with lathis, dangs, and a 12-bore double-barrel gun, attacked Puran Singh and his relatives:

A-1, A-2, and A-3 initiated the attack using brickbats and lathis.
A-4 fired multiple gunshots, causing fatal injuries.
Two victims Karam Singh and Laddi succumbed to gunshot injuries.

The prosecution argued that the accused acted with a common intention to kill the victims in retaliation for the earlier altercation.

Legal Proceedings

Trial Court Conviction

The Sessions Court convicted A-1, A-2, and A-3 under Sections 148, 302, and 307 IPC read with Section 34 IPC.
A-4 was convicted under Sections 148, 302, and 307 IPC and Section 27 of the Arms Act for using a firearm.
All the accused were sentenced to life imprisonment.
Co-accused A-5 was acquitted due to lack of evidence.

Appeal in the Punjab and Haryana High Court

The High Court upheld the conviction and sentencing of A-1, A-2, A-3, and A-4.
The defense’s argument that A-4 fired in self-defense was rejected.
It was ruled that the prosecution had proved the guilt of the accused beyond a reasonable doubt.

Appeal Before the Supreme Court

The appellants challenged their conviction before the Supreme Court on the following grounds:

A-1 and A-3 were juveniles at the time of the offense.
The High Court incorrectly applied Section 34 IPC (common intention) instead of Section 149 IPC (unlawful assembly).
The prosecution failed to examine independent witnesses despite the crime scene being in a public area.
The medical evidence did not support the prosecution’s version.
A-4 acted in self-defense as he was attacked first.

Supreme Court’s Observations

The Supreme Court, comprising Justices Dipankar Datta and Augustine George Masih, reviewed the evidence and reaffirmed the conviction.

1. Common Intention Was Clearly Established

The accused arrived at the scene armed and ready to retaliate.
The murder was premeditated and not a spontaneous act of self-defense.
The application of Section 34 IPC was justified since the accused shared a common intention to kill.

2. Self-Defense Claim Was Rejected

There was no evidence to support that A-4 was attacked first.
Instead, the victims suffered multiple gunshot wounds, proving a planned assault.
The Court emphasized that self-defense cannot be claimed by those who initiate aggression.

3. Non-Recovery of Firearm Was Not Fatal to the Prosecution’s Case

Eyewitnesses clearly identified A-4 as the shooter.
The Supreme Court ruled that forensic evidence is not mandatory if eyewitness testimony is strong.

4. Juvenility Claims Were Dismissed

The defense failed to prove the age of A-1 and A-3 at the time of the crime.
The Court ruled that merely stating juvenility is not enough; documentary proof is required.

Final Judgment

The Supreme Court ruled:

The conviction of A-1, A-2, and A-3 under Sections 148, 302, and 307 IPC read with Section 34 IPC was justified.
The conviction of A-4 under Sections 148, 302, 307 IPC, and Section 27 Arms Act was upheld.
The appeal was dismissed, affirming the life sentences imposed by the lower courts.
The ruling reaffirmed the principle of vicarious liability in group crimes.

Implications of the Judgment

This ruling has significant legal implications:

Reaffirmation of Section 34 IPC: The Court reiterated that when multiple individuals act with a common intention, all are equally liable.
Self-Defense Limitations: The judgment clarifies that a claim of self-defense is not valid when the accused are the aggressors.
Judicial Approach to Eyewitness Testimonies: The Court upheld the principle that reliable eyewitness accounts can override forensic gaps.
Finality in Criminal Convictions: The judgment discourages frivolous appeals and strengthens judicial consistency in serious crimes.

The Supreme Court’s decision underscores the need for a strict legal approach toward group crimes, ensuring that individuals involved in premeditated acts of violence do not escape justice due to technical defenses.

Petitioner Name: Baljinder Singh @ Ladoo & Others.
Respondent Name: State of Punjab.
Judgment By: Justice Dipankar Datta, Justice Augustine George Masih.
Place Of Incident: Punjab, India.
Judgment Date: 25-09-2024.

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