Court’s Decision
The Supreme Court set aside the conviction and death sentence of the appellant who had been accused of murdering four members of his family and injuring two others. Finding the prosecution’s case riddled with contradictions, unreliable eyewitnesses, and a glaring lack of corroborative forensic evidence, the Court held:
“It would be nothing short of a travesty of justice if a person is condemned to the gallows based on such shaky and improbable testimony.”
The Court noted that the prosecution had failed to prove the appellant’s guilt beyond reasonable doubt and emphasized that suspicion, however grave, cannot replace proof.
Facts
The case arose from an incident on 29 November 2013, where four family members—two adult women and two children—were found murdered and two others seriously injured in their residence. The accused, the husband of one of the deceased and father of two of the children, was alleged to have attacked them with a gandasi (a bladed weapon). The FIR was filed by the complainant (PW1), who claimed to have seen the accused fleeing the scene. The prosecution’s case relied on testimonies of three key witnesses: the complainant (PW1), his mother (PW2), and a surviving child (PW17).
Issues
- Whether the conviction could be sustained solely based on the testimonies of the prosecution witnesses, particularly PW1 and PW2.
- Whether the “rarest of rare” doctrine was rightly invoked for sentencing the appellant to death.
- Whether the alleged recoveries and motive were sufficient to link the accused to the crime.
Petitioner’s Arguments
The appellant argued that the prosecution failed to prove the case beyond reasonable doubt. The primary contentions included:
- The alleged motive (a financial dispute over unpaid maintenance) was unsupported by direct evidence, and neither of the principal parties to the dispute were examined.
- Eyewitness testimonies (PW1 and PW2) contained glaring contradictions, including inconsistencies regarding the timing, presence at the scene, and details of the weapon used.
- The alleged recoveries were made two months after the incident without any independent witnesses, raising serious doubts about their reliability.
- No forensic evidence linked the recovered items to the accused or the deceased.
- Even assuming conviction, the death penalty was disproportionate.
Respondent’s Arguments
The State contended that:
- The statements of PW2 and the injured child (PW17) sufficiently established the presence of the accused at the scene.
- The motive was clear and corroborated by village witnesses.
- The recoveries and the accused’s own injuries on the day of the incident added to the chain of circumstantial evidence.
- The brutality of the crime, involving minors, warranted capital punishment.
Analysis of the Law
The Court reiterated that the standard of proof in criminal trials is “beyond reasonable doubt,” and minor inconsistencies can be overlooked only when the core of the prosecution’s case remains intact. Here, however, the Court found the inconsistencies to be material.
It also held that the absence of independent witnesses, especially in a case involving neighborhood killings, was a significant lapse. The Court emphasized:
“The prosecution timeline and the fundamental details about the occurrence are not at all corroborated between its two key witnesses.”
Precedent Analysis
The Court referred to:
- Narayan Chetanram Chaudhary v. State of Maharashtra (2000): Only material contradictions undermine credibility.
- Vadivelu Thevar v. State of Madras (1957): If eyewitnesses are unreliable, corroboration is essential.
- State of Himachal Pradesh v. Lekh Raj (2000): Minor inconsistencies may be ignored, but not material ones.
- State of Rajasthan v. Kalki (1981): Discrepancies must be of such magnitude that they affect the credibility of witnesses.
Court’s Reasoning
The Court carefully analysed the testimonies of PW1, PW2, and PW17. It noted:
- PW1’s claim of witnessing the accused leaving the house was dubious as he lived 10 km away, not adjacent as earlier claimed.
- PW2’s version of hiding in bushes and being present during the attack was riddled with internal contradictions and failed to establish her presence convincingly.
- PW17, the child witness, admitted during cross-examination that he was asleep during the attack and did not see the accused inflicting injuries.
The Court also criticized the investigation, particularly:
- Lack of independent witness during recovery of weapon and blood-stained clothes.
- No forensic analysis to match blood to the victims.
- The alleged murder weapon was reportedly lost by the police later.
The Court held:
“Once the testimonies of PW1 and PW2 are discarded, and PW17 does not witness the crime, the prosecution’s case collapses.”
Conclusion
Setting aside the conviction and death penalty, the Court acquitted the appellant, observing:
“Suspicion, however grave it may be, cannot substitute proof. The prosecution, in the instant case, has completely failed in proving its case beyond reasonable doubt.”
Implications
This judgment serves as a critical reminder of the importance of adhering to evidentiary standards in criminal cases, especially those involving the death penalty. The Court’s observations underscore that courts must resist the temptation to convict on emotional grounds, particularly in heinous crimes, and must rely solely on reliable and cogent evidence.
Cited Cases Summary
- Narayan Chetanram Chaudhary v. State of Maharashtra: Minor contradictions don’t affect credibility unless they touch upon core facts.
- Vadivelu Thevar v. State of Madras: Differentiated between wholly reliable and partly reliable witnesses.
- State of Rajasthan v. Kalki: Material discrepancies must go to the root of the matter to discredit testimony.
FAQs
1. Can a person be convicted based solely on inconsistent eyewitness testimony?
No. The Supreme Court reiterated that contradictory and unreliable testimonies, unless corroborated by independent or forensic evidence, cannot form the basis for conviction.
2. What is required to prove murder beyond reasonable doubt?
The prosecution must establish a clear chain of events backed by credible witness testimony, forensic evidence, and motive—free from material contradictions or gaps.
3. When is the death penalty justified?
The “rarest of rare” doctrine applies only when the crime shocks the collective conscience and the guilt is proven conclusively. A mere heinous nature of crime is insufficient without solid evidence.