The case involved a man who was accused of murdering one Ramlal. He had been convicted under Section 302 of the Indian Penal Code (IPC) and sentenced to life in prison. However, the Supreme Court, while hearing his appeal, found that the evidence against him was not strong enough to prove his guilt beyond doubt.
NEW DELHI: The Supreme Court of India ruled a life sentence given to a man in a murder case. The court ruled that there was no solid proof that he committed the crime. The case was about an alleged dispute over unpaid or delayed wages, but the judges stated that such a small issue was not a strong enough reason to commit a murder.
Background
The case involved a man who was accused of murdering one Ramlal. He had been convicted under Section 302 of the Indian Penal Code (IPC) and sentenced to life in prison. However, the Supreme Court, while hearing his appeal, found that the evidence against him was not strong enough to prove his guilt beyond doubt.
The Division Bench, comprising Justice Pankaj Mithal and Justice Ahsanuddin Amanullah, observed: “The issue of non-payment of wages is hardly material and is so trivial a matter so as to compel anyone to take an extreme step of committing a crime of such a grave nature. Moreover, there is no material evidence to prove any discord between the two.”
The accused was represented by Advocate-on-Record Rukhsana Choudhury, while the Respondent was represented by Advocate Abhishek Pandey.
According to the allegations, the accused was living with the deceased and working for him. On the day of the incident, the accused left on a cycle with a bag but returned after two hours, saying that his cycle had a puncture. He asked the deceased’s wife for money to repair it. To arrange money, she went to the market to sell paddy, leaving her husband and the accused at home.
When she returned, she reportedly saw the accused running away, holding a farsi (a sharp weapon). She then found her husband lying on the ground, bleeding heavily, with his neck severed.
It was suspected that the accused killed Ramlal due to unpaid or delayed wages. The prosecution argued that:
- The accused was the last person seen with the victim.
- The murder weapon (farsi) was found based on the accused’s information.
- The injuries on the deceased matched those caused by a farsi.
Based on this circumstantial evidence, the lower courts convicted him and sentenced him to life imprisonment.
The Supreme Court examined the case under the principles of circumstantial evidence, referring to the 1984 landmark case Sharad Birdhichand Sarda vs State of Maharashtra. This case laid down five essential conditions (also called Panchsheel principles) for proving guilt based purely on circumstantial evidence:
- The circumstances must be fully established.
- The facts must clearly point towards the guilt of the accused.
- There should be no other reasonable explanation except the accused’s guilt.
- The evidence must form a complete chain, ruling out any chance of innocence.
- The crime must be proven to have been committed by the accused beyond reasonable doubt.
Referring to these principles, the Bench remarked: “In other words, the chain of events leading to the prosecution of the convict must conclusively be established with certainty and there shall not be any room for any second opinion which may lead to the innocence of the accused.”
The court noted that while the accused was alleged to have a motive due to unpaid wages, this reason alone was not sufficient proof.
The Bench stated: “However, such a discord is not of such a nature of extent which may lead to such a drastic action on part of the appellant to kill the deceased.”
- Lack of independent witness testimony:
- The prosecution claimed the accused was last seen with the deceased before the murder. However, the only witness to this claim was the victim’s wife. There was no independent witness to confirm that the accused returned home as alleged.
- The Bench observed: “The fact that the appellant-accused actually returned as alleged was not established by any independent evidence except for the statement of the wife of the deceased.”
- Doubts over the accused’s presence at the scene:
- The police recovered the accused’s cycle but did not check whether the tyres were really punctured, which could have supported the claim that he returned home after two hours.
- Doubtful recovery of the weapon:
- The farsi was recovered 20-25 days after the crime, on the accused’s statement. Though it had bloodstains, no forensic report was submitted to match it with the deceased’s blood.
- The court noted: “Merely for the reason that the doctor opined that the injuries on the deceased may have been caused by a similar weapon would not conclude that the recovered farsi was the weapon of crime.”
- Contradictions in the wife’s statement:
- The wife claimed she saw the accused running away, but the Bench pointed out that she had already said he had fled before she reached home.
- The court said: “As per the Bench, it couldn’t be conclusively established that the witness saw the appellant running or fleeing from the place of crime.”
Since the prosecution failed to establish a strong and unbroken chain of evidence, the court ruled that there was reasonable doubt about the accused’s involvement. The Supreme Court, therefore, allowed the appeal and set aside the conviction.
The Bench stated“Thus, the Bench allowed the appeal as the circumstances raising a finger upon the appellant, were not conclusive to prove beyond the shadow of a doubt that the appellant was the person responsible for the commission of the crime.”
Additionally, the court considered that the accused had already spent over 10 years in prison. Since his guilt was not proven beyond doubt, he was acquitted.
Case Title: Hansraj v. State of Chhattisgarh
