Court’s Decision
The Madras High Court allowed the appeal, setting aside the conviction and sentence imposed by the Trial Court under Section 302 of the Indian Penal Code. The Court held that the prosecution had failed to establish the guilt of the accused beyond reasonable doubt. It particularly emphasized the unexplained injuries sustained by the accused, the inconsistencies in the prosecution’s version, and the credible testimony of the defence witness. The Court concluded that the benefit of doubt must be extended to the accused and that the conviction cannot be sustained.
“When there is a definite version that the accused was not at the place of occurrence and when such evidence was not shaken in cross-examination, then the Court cannot simply ignore the said evidence.”
Facts
The accused was charged with murdering the deceased by stabbing him with a knife. The alleged incident occurred in front of a tea shop in the presence of prosecution witnesses. The prosecution claimed that the motive was a prior enmity due to the accused and the deceased often quarrelling. It was stated that the accused suddenly came to the tea shop and stabbed the deceased with a knife on his neck and chest, resulting in death.
An eyewitness stated that he was talking with the deceased when the accused arrived and committed the act. The injured deceased was taken to the Government Hospital, but he succumbed to the injuries. The accused, on the other hand, had also sustained injuries and was found at a different hospital. The prosecution did not offer any explanation for these injuries.
The defence put forth an alibi through DW-1, who testified that the accused was not present at the scene but at a different location due to a quarrel earlier in the day. This version was not discredited in cross-examination.
Issues
- Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the offence under Section 302 of the Indian Penal Code?
- Whether the non-explanation of injuries sustained by the accused creates a doubt about the prosecution version?
- Whether the testimony of the defence witness establishes a reasonable alibi?
Petitioner’s Arguments
The prosecution contended that the case was proved through eyewitnesses who saw the accused stabbing the deceased in broad daylight. The presence of motive due to frequent quarrels between the deceased and the accused was highlighted. It was argued that the recovery of the knife at the instance of the accused and the medical evidence corroborating the injuries sustained by the deceased further strengthened the prosecution’s case.
The prosecution also contended that minor inconsistencies should not lead to an acquittal when the evidence of the eyewitnesses was otherwise consistent and trustworthy.
Respondent’s Arguments
The defence emphasized that the accused had suffered serious injuries, and the prosecution failed to explain how those injuries were caused. This omission was described as a fatal flaw in the prosecution’s case. It was further argued that the medical evidence regarding the time of injuries to the accused was inconsistent with the prosecution’s version, raising serious doubts.
The defence relied heavily on the testimony of DW-1, who stated that the accused was not at the place of occurrence and had actually gone to a hospital after being attacked. This evidence was unshaken in cross-examination and not rebutted by the prosecution.
Analysis of the Law
The Court reiterated the settled legal position that the prosecution must explain injuries sustained by the accused if they are serious and sustained at or around the time of the incident. Failure to do so would entitle the accused to the benefit of doubt.
The Court also noted that the right of the accused to lead evidence under Section 105 of the Evidence Act includes the right to put forth a reasonable explanation or alternative version. When such evidence is credible and unshaken, it must be given due weight.
Precedent Analysis
- Lakshmi Singh v. State of Bihar (1976) 4 SCC 394 – The Supreme Court held that if the prosecution fails to explain injuries on the accused, it casts a serious doubt on the prosecution case.
- State of Rajasthan v. Madho (1991) 4 SCC 432 – Reaffirmed that unexplained injuries on the accused are an important factor when assessing whether the prosecution has proved its case beyond reasonable doubt.
- State of Uttar Pradesh v. Ram Swarup (1974) 4 SCC 764 – Held that the failure to explain the injuries on the accused weakens the prosecution story.
These cases were relied upon by the High Court to reinforce that unexplained injuries are not merely minor oversights but may fundamentally affect the credibility of the prosecution’s case.
Court’s Reasoning
The Court observed that the eyewitness accounts, though identifying the accused, suffered from contradictions and exaggerations. More critically, the prosecution did not offer any explanation for the accused’s injuries. The injuries were found to be serious, and medical evidence showed that the accused had been assaulted.
Further, the Court found the defence witness credible. DW-1 had categorically stated that the accused was not present at the scene of occurrence and was instead assaulted in a different place. This testimony was not shaken in cross-examination.
The Court held:
“In view of the above analysis, we are of the firm view that the prosecution has not established the case against the accused beyond reasonable doubt.”
Conclusion
The High Court allowed the appeal and acquitted the accused. The conviction and sentence under Section 302 IPC were set aside. The accused was directed to be released if not required in any other case. The Court held that the benefit of doubt must be extended due to the unexplained injuries, inconsistencies in prosecution testimony, and the credible defence version.
Implications
This judgment reinforces that unexplained injuries on the accused are not a mere procedural lapse but go to the root of the prosecution’s case. It affirms that the prosecution cannot pick and choose the facts to present, and all relevant circumstances must be explained. The ruling also underscores the importance of treating defence witnesses on par with prosecution witnesses.
Cases Referred
- Lakshmi Singh v. State of Bihar, (1976) 4 SCC 394 – Cited to establish that failure to explain injuries on the accused renders the prosecution case doubtful.
- State of Rajasthan v. Madho, (1991) 4 SCC 432 – Referred for the principle that serious injuries on the accused must be explained.
- State of Uttar Pradesh v. Ram Swarup, (1974) 4 SCC 764 – Relied upon to show that such failures weaken the entire prosecution case.
FAQs
1. What is the significance of not explaining injuries on the accused in a murder trial?
Unexplained injuries on the accused raise serious doubts about the prosecution’s version and may indicate that the accused acted in self-defence or that the incident occurred differently from what is alleged.
2. Can the testimony of a defence witness outweigh that of prosecution witnesses?
Yes. If the defence witness is credible and their testimony is not discredited in cross-examination, the court can rely on it to acquit the accused.
3. What happens if the prosecution’s eyewitnesses contradict each other?
Contradictions in eyewitness testimonies, especially regarding material particulars, weaken the prosecution case and may lead to acquittal if the overall story becomes unreliable.
