In a landmark judgment, the Supreme Court of India underscored the principle of giving the benefit of doubt to the accused in cases where an appellate court can form a view different from that of the trial court. This observation came during the reversal of a 2007 murder case conviction by a bench comprising Justices Abhay S Oka and Pankaj Mithal.
The case involved three individuals convicted by both the trial court and the High Court for a murder that occurred in 2007. The Supreme Court, however, found grounds to reconsider the verdict. Justice Oka stated,
“We are conscious of the fact that the appellate court should be slow in interfering with the conviction recorded by the courts below but where the evidence on record indicates the prosecution has failed to prove the guilt of the accused beyond reasonable doubt and that a plausible view, different from the one expressed by the courts below can be taken, the appellate court should not shy away in giving the benefit of doubt to the accused persons.”
The prosecution’s case was based on the dying declaration of the victim, Pappu alias Rajendra Yadav, who was allegedly assaulted by the accused near Machchu Hotel. However, the Supreme Court found inconsistencies in the dying declaration and the testimony of the prosecution witnesses. The court noted,
“The brother and the mother of the deceased had rushed to the spot only after receiving information of the incident from PW-1 who after seeing the accused persons assaulting the deceased had gone to their house to inform of the incident. All this, obviously, could have consumed 15-25 minutes which means that by the time they reached the place of occurrence, the deceased could not have survived so as to make any declaration.”
Furthermore, the court expressed skepticism about the reliability of the testimony provided by PW 13, Rahul Yadav, a relative of the deceased. The court observed,
“It has come in evidence that Rahul Yadav (PW-13) is a relative of the deceased Pappu Yadav and as such he is not a free and independent witness. He is likely to be an interested witness.”
The court emphasized that such testimony should be considered with caution and not be blindly relied upon without corroborative evidence.
After a thorough analysis of the evidence and testimonies, the Supreme Court found that the dying declaration of the deceased was not corroborated by other cogent evidence. Consequently, the court granted the benefit of doubt to the appellant-accused, setting aside their conviction and sentence, thereby setting them free and discharging their bail bond.
This ruling by the Supreme Court highlights the importance of careful scrutiny of evidence and testimonies in criminal cases, especially at the appellate level. It reinforces the principle that the benefit of doubt should be given to the accused if there is a possibility of a different interpretation of the evidence than what was concluded by the lower courts. This judgment serves as a significant precedent in ensuring justice and fairness in the judicial process.
