The Supreme Court acquitted four men in a 30-year-old murder case, citing contradictions in eyewitness accounts and unclear circumstances of the incident. The judgment reinforces that conviction cannot be sustained in case the genesis of the incident is doubtful.
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NEW DELHI: In a judgment highlighting the principle of the benefit of doubt, the Supreme Court of India recently acquitted four men convicted in a murder case that dates back over three decades. The Apex Court emphasized that when the genesis and manner of an incident remain doubtful, and the prosecution’s version suffers from material contradictions, conviction cannot be sustained.
Background of the Case
The case originated from a complaint lodged by the father of the deceased, alleging that ten men, including the appellant, attacked his son during a dispute over the dismantling of a temporary hutment. The deceased later succumbed to injuries, leading to charges under Section 302 of the Indian Penal Code (IPC).
During the trial, the prosecution presented 18 witnesses, including two alleged eyewitnesses. The Trial Court convicted four accused and acquitted six others. The Madhya Pradesh High Court upheld the conviction. However, the appellant alone approached the Supreme Court, challenging the judgment because the evidence contained contradictions and inconsistencies regarding the place and manner of the incident.
Supreme Court’s Observations
A Bench comprising Justice Sanjay Karol and Justice Sandeep Mehta closely examined the testimonies of the two eyewitnesses. The Court observed:
- The accounts of the witnesses were mutually contradictory and did not align with the First Information Report (FIR).
- One witness stated the incident occurred near a field, while the other claimed it happened near a hutment.
- Each witness denied the presence of the other at the scene.
- Their statements conflicted with the site inspection plan and medical evidence.
The Court reiterated the principle laid down in Pankaj v. State of Rajasthan (2016): when the genesis and manner of the incident are doubtful, conviction cannot be sustained. Further, citing Bhagwan Sahai v. State of Rajasthan, it held that when the prosecution suppresses or fails to clarify the origin and nature of the occurrence, the accused must be given the benefit of doubt.
The Supreme Court highlighted that there was no credible explanation regarding the cause of the alleged altercation or the precise location of the assault. The shifting narratives of the prosecution undermined the credibility of the entire case.
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Considering the contradictions and inconsistencies, the Supreme Court concluded that the prosecution failed to prove the case beyond a reasonable doubt. Exercising powers under Article 142 of the Constitution, the Court not only acquitted the appellant but also extended the benefit of doubt to the three other co-convicts who had not filed appeals.
The Supreme Court allowed the appeal and set aside the orders of the Madhya Pradesh High Court, effectively acquitting all four convicted persons.
Appearances:
Appellant: Advocates Pukhrambam Ramesh Kumar, AOR, Karun Sharma, Anupama Ngangom, Rajkumari Divyasana
Respondent: Advocates Pashupathi Nath Razdan, AOR, Aditya Vaibhav Singh, Abhinav Srivastav
Case Title:
KANNAIYA VERSUS STATE OF MADHYA PRADESH
CRIMINAL APPEAL NO(S). 116 OF 2012
READ JUDGMENT
