Supreme Court Upholds Murder Conviction in Delhi Stabbing Case

The case of Chandan vs. The State (Delhi Administration) revolves around the conviction of the appellant for a daylight murder under Section 302 of the Indian Penal Code (IPC). The Supreme Court had to determine whether the conviction, based primarily on eyewitness testimony and forensic evidence, was justified.

The Court upheld the conviction, emphasizing that reliable eyewitness accounts and corroborating forensic evidence are sufficient to establish guilt beyond a reasonable doubt, even in the absence of a clear motive.

Background of the Case

The incident took place on May 28, 1993, at approximately 8:15 PM. The deceased, Rakesh, was walking with the accused, Chandan, a few steps ahead of PW-2, the deceased’s sister-in-law. According to the prosecution, a physical altercation ensued between the deceased and the accused, following which the accused stabbed the deceased multiple times and fled the scene.

The deceased was initially taken to a private clinic, but doctors there advised shifting him to Hindu Rao Hospital. By the time he reached the hospital, he was declared dead.

A post-mortem examination conducted the following day, May 29, 1993, revealed multiple incised stab wounds:

Injury on the left clavicular area (collar bone region).
Wound below and medial to the left nipple.
Multiple deep incised wounds on the left arm, chest, and back.
Critical injury on the left lateral chest wall at the seventh rib, which punctured the pericardium and left ventricle of the heart.

The forensic report confirmed that injury no. 5 was sufficient in the ordinary course of nature to cause death.

Key Legal Issues

Whether the eyewitness testimony of PW-2 was reliable.
Whether the forensic and circumstantial evidence corroborated the prosecution’s version of events.
Whether the lack of motive weakened the prosecution’s case.

Arguments by the Appellant

The appellant challenged the conviction, arguing:

“The prosecution has failed to establish any motive behind the alleged crime, which casts doubt on the entire case.”

Additionally, the defense questioned the credibility of PW-2, the primary eyewitness, suggesting that her testimony was inconsistent.

Arguments by the Respondent

The prosecution countered:

“The testimony of PW-2 is consistent and reliable. Her account of events is corroborated by forensic evidence, including the blood-stained knife recovered from the accused.”

The State also argued that motive, while relevant, is not a necessary element when direct eyewitness testimony establishes guilt.

Supreme Court’s Analysis

1. Reliability of Eyewitness Testimony

The Court examined the testimony of PW-2, ruling:

“She was subjected to lengthy cross-examination, but nothing was elicited to discredit her account. She clearly witnessed the accused stabbing the deceased multiple times.”

The Court emphasized that eyewitness testimony, when consistent and credible, can be the sole basis for conviction.

2. Corroboration by Forensic and Circumstantial Evidence

The Court noted that the accused was apprehended on the same day, near the crime scene, with the murder weapon in his possession. The forensic report confirmed:

“The blood on the knife matched that of the deceased, further corroborating the prosecution’s case.”

The rapid sequence of events—murder, arrest, and weapon recovery—left little room for doubt regarding the accused’s involvement.

3. Absence of Motive and its Legal Impact

The defense’s argument regarding the absence of motive was dismissed, with the Court citing precedent from Shivaji Genu Mohite v. State of Maharashtra (1973):

“When direct eyewitness testimony inspires confidence, the prosecution is not required to establish motive. Absence of motive does not impinge upon the testimony of a reliable witness.”

The Court reiterated that motive is significant in cases based purely on circumstantial evidence but not when a credible eyewitness account exists.

Final Judgment

The Supreme Court dismissed the appeal, ruling:

“The prosecution has proved its case beyond a reasonable doubt. The conviction and sentence under Section 302 IPC are upheld.”

The Court directed the appellant, who was out on bail, to surrender within four weeks to serve the remaining sentence.

Key Takeaways from the Judgment

Reliable eyewitness testimony is sufficient to sustain a murder conviction.
Corroborating forensic evidence, such as matching blood samples, strengthens the prosecution’s case.
The absence of motive does not weaken the case when there is direct evidence of the crime.
Quick recovery of the murder weapon and immediate arrest bolster the credibility of the prosecution’s version of events.
The Court prioritizes the integrity of eyewitness testimony over hypothetical doubts regarding motive.

Judgment Date: April 5, 2024

Judges: Sudhanshu Dhulia, Prasanna B. Varale

Petitioner Name: Chandan.
Respondent Name: The State (Delhi Administration).
Judgment By: Justice Sudhanshu Dhulia, Justice Prasanna B. Varale.
Place Of Incident: Kashmere Gate, Delhi.
Judgment Date: 05-04-2024.

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