“The prosecution has not established its case beyond reasonable doubt due to material contradictions affecting the core facts, requiring the benefit of doubt to be given to the accused.”
Court’s Decision
The Patna High Court allowed the criminal appeal, setting aside the conviction under Sections 304 and 307 of the IPC and the corresponding sentences passed by the Additional District and Sessions Judge, FTC-I, Ara, Bhojpur. The Court acquitted the appellants of all charges and discharged them from their bail bonds, holding that serious contradictions in the prosecution evidence and failure to establish intention to kill warranted acquittal.
Facts
The case arose from an altercation during wrestling on the occasion of Gobardhan Puja on 24 October 1995 near Kali Mandir, Village Amiya, Bhojpur. An altercation led to a group assault on the deceased Vishnudeo Yadav and the informant Jitendra Yadav with lathis and bricks, resulting in injuries to both. Vishnudeo succumbed to head injuries during treatment, and the police registered a case under Sections 302, 307, and 304 IPC. The trial court convicted the appellants, sentencing them to 10 years (under Section 304) and 7 years (under Section 307) for one appellant and 7 and 5 years for the others, respectively, leading to the present appeal.
Issues
- Whether the prosecution proved beyond reasonable doubt that the appellants committed culpable homicide and attempted murder.
- Whether the contradictions in witness testimonies affected the core case of the prosecution.
- Whether the appellants were entitled to acquittal due to the benefit of doubt.
Petitioner’s Arguments
- The prosecution’s case was contradictory, with discrepancies between the FIR and witness statements, including inconsistencies about the sequence of events and manner of injuries.
- PW-1’s medical evidence showed superficial injuries on the informant, contradicting his claims of severe assault.
- PW-2 and PW-3 gave conflicting versions about the deceased’s movement post-injury, with PW-2 claiming he was taken home, while others said he was taken directly to the hospital.
- The investigating officer found no bloodstains, wrestling arena, or bricks at the place of occurrence, raising doubts about the prosecution story.
- Cited State of Maharashtra v. Kashirao, State of U.P. v. M.K. Anthony, Babu v. State of Kerala, and Vikas v. State of Maharashtra to assert that serious contradictions in prosecution evidence require benefit of doubt to the accused.
Respondent’s Arguments
- The prosecution argued that witness testimonies consistently implicated the appellants in the assault on the deceased and the informant.
- Any contradictions were minor and did not affect the core case.
- The trial court had correctly appreciated the evidence and convicted the appellants based on the consistent testimony of injured eyewitnesses and medical reports.
Analysis of the Law
- The essential ingredients for conviction under Section 307 IPC require proof of intention or knowledge to cause death (State of Maharashtra v. Kashirao).
- Serious contradictions affecting the core facts and consistency of prosecution evidence require acquittal due to the benefit of doubt (State of U.P. v. M.K. Anthony; Babu v. State of Kerala; Vikas v. State of Maharashtra).
- The prosecution must establish the place, manner, and motive of occurrence beyond reasonable doubt.
Precedent Analysis
- State of Maharashtra v. Kashirao (2003): Clarified the need for proving intent and knowledge in attempts to murder.
- State of U.P. v. M.K. Anthony (1985): Emphasised the impact of serious contradictions on prosecution reliability.
- Babu v. State of Kerala (2010): Stressed trustworthy and consistent evidence for conviction, requiring benefit of doubt in case of contradictions.
- Vikas v. State of Maharashtra (2008): Highlighted the need for consistency between FIR and depositions for upholding conviction.
These cases collectively supported the acquittal in the present case.
Court’s Reasoning
- Witnesses PW-2, PW-3, and PW-4 gave materially contradictory statements about:
- Whether the deceased was taken home or directly to the hospital
- The precise location and sequence of the assault.
- The nature and cause of injuries.
- The investigating officer found no physical evidence supporting the place and manner of the alleged incident.
- The medical evidence did not align with claims of multiple injuries from lathis and brick-batting, showing only a single head injury.
- The contradictions were material, affecting the core of the prosecution’s case and creating reasonable doubt about the guilt of the appellants.
- The prosecution failed to establish the offence beyond reasonable doubt, warranting acquittal.
Conclusion
The Patna High Court acquitted the appellants of charges under Sections 304 and 307 IPC, setting aside the conviction and sentence due to material contradictions in prosecution evidence and failure to prove the case beyond reasonable doubt. The appellants were discharged from their bail bonds.
Implications
- Reinforces the principle that serious contradictions in evidence warrant acquittal due to benefit of doubt.
- Clarifies that courts require consistency and corroboration in witness testimonies to sustain convictions in serious offences.
- Highlights the need for the prosecution to establish intention and the manner of the offence beyond reasonable doubt for convictions under Sections 304 and 307 IPC.
Brief Note on Cases Referred
- State of Maharashtra v. Kashirao: On proving intent under Section 307 IPC.
- State of U.P. v. M.K. Anthony: Serious contradictions may require acquittal.
- Babu v. State of Kerala: Evidence must be consistent and trustworthy.
- Vikas v. State of Maharashtra: Importance of consistency between FIR and witness depositions.
These were applied to support the Court’s reasoning in acquitting the appellants.
FAQs
1. Can contradictions in witness testimonies lead to acquittal?
Yes, serious contradictions affecting core facts can lead to acquittal by creating reasonable doubt.
2. What must be proven for conviction under Section 307 IPC?
The prosecution must prove an intention to cause death or knowledge that the act was likely to cause death.
3.What is the effect of lack of physical evidence at the crime scene?
It weakens the prosecution case, especially when inconsistencies exist, supporting the defence of false implication.
