In a recent verdict, the Supreme Court of India underscored the importance of the quality of evidence, particularly concerning extra-judicial confessions, in a murder case. The apex court acquitted a convict, emphasizing that evidence from individuals before whom an extra-judicial confession is made must be of “sterling quality.”
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The bench, comprising Justices Abhay S. Oka and Pankaj Mithal, raised doubts about the credibility of the extra-judicial confession made before PW-2 and PW-3, who were the brothers of the deceased. The court found it unusual for an accused to confess before individuals so closely related to the victim. The court observed,
“When prosecution relies upon the evidence of extra-judicial confession, normally, the Court will expect that the evidence of the persons before whom extra-judicial confession is allegedly made must be of sterling quality.”
The case dates back to November 12, 1997, involving the death of Hukabhai. The appellant was convicted under Section 302 IPC (murder), a decision upheld by the Gujarat High Court. The trial primarily relied on the accounts of key witnesses, including PW-2 (Kalabhai) and PW-3 (Ramabhai), both closely connected to the deceased. According to the prosecution, the appellant allegedly assaulted Hukabhai with a bamboo stick. Eyewitnesses claimed that the accused followed the victim to his field and returned to the village with the same stick. The appellant supposedly confessed to the assault before PW-2, PW-3, and another individual named Ratabhai.
A crucial aspect of the defense’s case was the inconsistency in blood stains found on the accused’s clothes at the time of arrest. The Serology Report revealed conflicting blood groups, weakening the prosecution’s argument. Additionally, the court dismissed the significance of the recovered axe, as eyewitnesses attested that the appellant used a stick, not an axe.
Given the inconclusive evidence and the lack of conclusive proof of guilt, the Supreme Court acquitted the appellant. The judgment highlighted the need for the prosecution to establish guilt beyond a reasonable doubt. The case, titled PRABHATBHAI AATABHAI DABHI v. STATE OF GUJARAT, becomes a significant reference in the context of the evidentiary value of extra-judicial confessions in criminal trials.
