Supreme Court Upholds Murder Conviction: Section 34 IPC and Common Intention Explained

The Supreme Court of India, in the case of Rameshwar & Anr. vs. State of Madhya Pradesh, examined the application of Section 34 IPC in a murder case and upheld the life imprisonment sentence of the accused. The Court reinforced the principle of common intention and ruled that inconsistencies in witness statements do not necessarily weaken a prosecution case if the core evidence remains intact.

Background of the Case

The case arose from the brutal murder of Ram Autar, which occurred on January 8, 1984, in Saidapur village, Madhya Pradesh. The prosecution alleged that the murder was the result of a long-standing rivalry between the deceased and the accused, Rameshwar and Balaram. The incident occurred while Ram Autar was having a meal at home. He stepped out into the courtyard to drink water when Rameshwar, armed with a farsa (axe), and five other accused, armed with rifles and sticks, confronted him.

Rameshwar exhorted others to kill Ram Autar and attacked him with the axe. Ram Autar tried to escape but was caught by four men at the doorstep of Kedar Seth’s house. Meanwhile, Ram Autar’s mother, Tejabai, attempted to shield him, but the accused separated her. Accused Balaram fired a gunshot at Ram Autar, hitting him in the back, and Rameshwar, after snatching a gun from another accused, fired another shot at Ram Autar, leading to his death. The accused fled when villagers arrived at the scene.

Key Legal Issues

Whether the delay in registering the FIR affected the prosecution’s case.
Whether the inconsistencies in eyewitness statements weakened the case.
Whether the trial court and High Court correctly applied Section 34 IPC to convict both accused.
Whether the forensic and medical evidence corroborated the prosecution’s version of events.

Arguments by the Appellants (Accused)

The accused contended:

The delay in registering the FIR raised doubts about the authenticity of the prosecution’s claims.
The eyewitness statements of PW-1 (Subhadra), PW-2 (Ram Narayan), PW-6 (Katori Bai), and PW-7 (Ram Gopal) contained contradictions and could not be relied upon.
There was no clear evidence to establish common intention, and Section 34 IPC was wrongly invoked.
The prosecution failed to prove which of the accused inflicted the fatal injury.

Arguments by the Respondents (State of Madhya Pradesh)

The State argued:

The FIR delay was minor and sufficiently explained, and it did not affect the credibility of the prosecution’s case.
The eyewitnesses were consistent in stating that the accused were present at the crime scene and had attacked the deceased.
Section 34 IPC was applicable because both accused actively participated in the murder and had a common intention.
The forensic evidence, including the post-mortem report, confirmed that the gunshot wounds matched the injuries described by witnesses.

Supreme Court’s Observations

1. FIR Delay Not Fatal to Prosecution Case

The Court ruled that while there was a delay in the FIR reaching the Magistrate, it was not unreasonable or unexplained. It stated:

“The delay in registering the FIR does not, by itself, create doubt unless it is unexplained. Here, the prosecution has sufficiently explained the circumstances leading to the delay.”

2. Reliability of Eyewitness Testimony

The Court upheld the reliability of PW-1, PW-2, PW-6, and PW-7, stating:

“The testimony of a close relative cannot be discarded merely on the ground of relationship if it is otherwise found credible and consistent with the prosecution’s case.”

3. Medical and Forensic Evidence

The post-mortem report confirmed that Ram Autar had sustained multiple gunshot wounds and injuries from a sharp weapon. The Court ruled:

“The post-mortem findings are consistent with the injuries described by the eyewitnesses, corroborating the prosecution’s version of the attack.”

4. Application of Section 34 IPC

The Court emphasized that for Section 34 IPC to apply, the prosecution must prove that multiple accused acted with a shared intent. It noted:

“To invoke Section 34 IPC, it must be established that the criminal act was done by more than one person in furtherance of a common intention. The presence of appellant No.2 has been established by consistent evidence of the eyewitnesses.”

Final Verdict

The Supreme Court ruled:

The conviction of Rameshwar (Appellant No.1) was abated due to his death during the appeal.
The conviction and life imprisonment sentence of Balaram (Appellant No.2) were upheld.
The appeal was dismissed, confirming the Madhya Pradesh High Court’s ruling.

Conclusion

This judgment reaffirms the principles governing common intention under Section 34 IPC. It clarifies that minor inconsistencies in eyewitness accounts do not necessarily undermine a case if the core prosecution evidence remains intact. The ruling also establishes that delay in FIR registration, if reasonably explained, does not automatically weaken the prosecution’s case. The Supreme Court’s decision ensures that substantive justice prevails in cases involving premeditated acts of violence.

Petitioner Name: Rameshwar & Anr..
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice R. Banumathi, Justice A.S. Bopanna.
Place Of Incident: Saidapur, Madhya Pradesh.
Judgment Date: 21-08-2019.

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