Court’s Decision
The Supreme Court of India has set aside the conviction of three appellants—father, son, and son-in-law—who were earlier sentenced to life imprisonment for the murder of one Pushpendra Singh. The Court held that the High Court erred in reversing the Trial Court’s acquittal without demonstrating that its findings were perverse, emphasizing that the identity of the accused as the actual assailants was not proved beyond reasonable doubt.
A Bench of Justices Pankaj Mithal and Prasanna B. Varale observed:
“The High Court manifestly erred in interfering with the findings of acquittal recorded by the Trial Court without concluding that such findings were perverse. It is safer to rely on the Trial Court, which has seen the demeanor of the witnesses.”
The appeals were allowed, and the appellants were acquitted by extending the benefit of doubt.
Facts
The prosecution alleged that on the morning of June 3, 2000, the appellants began digging the field of Diler Singh, father of the deceased, to lay a plinth. This led to a quarrel between the parties. Later that afternoon, the deceased, Pushpendra Singh, was sitting at the Jogither diversion when the appellants arrived on a motorcycle, allegedly armed with swords and a kanta (a sharp-edged weapon). On seeing them, the deceased ran towards the northern fields, crying for help, and was chased by the appellants.
In an attempt to save his life, the deceased entered the house of one Mukhtyar Singh. The appellants allegedly followed him inside and assaulted him with the weapons, resulting in his death on the spot. Diler Singh (father of the deceased) lodged an FIR under Section 302 IPC (now Section 103(1) BNSS) at 2:50 p.m. the same day. The accused were arrested within days, and the alleged weapons of offence were recovered based on their disclosure statements.
The Trial Court acquitted all accused, finding the prosecution’s case doubtful. However, the High Court reversed this acquittal and convicted them under Section 302 IPC, sentencing them to life imprisonment. The appellants challenged the conviction before the Supreme Court.
Issues
- Whether the High Court was justified in reversing the Trial Court’s acquittal without finding its conclusions perverse or unreasonable.
- Whether the evidence on record conclusively established the identity of the appellants as the actual perpetrators of the crime.
- Whether the recovery of the alleged weapons of offence could sustain conviction in the absence of conclusive forensic linkage to the crime.
Petitioners’ Arguments
The appellants argued that they were falsely implicated due to prior enmity. They contended that there were no credible eyewitnesses who could identify them as the assailants. The sole independent witness, a woman (PW-7) in whose house the deceased took refuge, did not know the accused and did not identify them during the investigation. Moreover, no test identification parade was conducted to link them to the crime scene.
The defence also pointed to major contradictions in the testimonies of the prosecution witnesses. They emphasized that the discovery of weapons under Section 27 of the Indian Evidence Act had no evidentiary value, as the forensic report linking the blood on the weapons to the deceased was never produced.
It was argued that the High Court’s reversal of acquittal was legally unsustainable as the Trial Court’s findings were not perverse or arbitrary. The appellants relied on the settled principle that when two views are possible, the one favouring acquittal must prevail.
Respondent’s Arguments
The State contended that the ocular evidence of the deceased’s father (PW-1), Jwala Singh (PW-2), and Amarjeet Kaur (PW-7) clearly established the appellants’ identity. The prosecution maintained that PW-7 witnessed the incident inside her house and described how the accused inflicted fatal blows on the deceased.
The State further submitted that the recovery of swords and a kanta based on the appellants’ disclosure confirmed their involvement. It was argued that the High Court rightly convicted the appellants after reappraising the evidence, as the Trial Court had erred in giving undue benefit of doubt.
Analysis of the Law
The Supreme Court reaffirmed the limited scope of interference with acquittals. A Trial Court’s acquittal can be reversed by an appellate court only if the findings are perverse, unreasonable, or based on misreading of evidence. The Bench emphasized that since the Trial Judge directly observed the demeanor of witnesses, its assessment of credibility must command deference unless patently erroneous.
The Court then analyzed the evidentiary weaknesses in the prosecution’s case:
- Eyewitness inconsistency: PW-7, the independent witness, admitted she did not know the accused and could not identify them. Her account revealed that the victim’s father and others arrived about half an hour after the attack, contradicting the claim of having witnessed the assault.
- Unreliable testimony: The father (PW-1) claimed to have hugged his son’s blood-stained body but did not hand over his clothes to the police, which the Court found “unnatural and fabricated.”
- Absence of identification parade: Police never conducted any formal identification process.
- Forensic lacunae: The bloodstains on recovered weapons were not matched with the deceased’s blood group; hence, no scientific evidence connected the weapons to the crime.
The Court concluded that the prosecution failed to establish identity beyond reasonable doubt, a core ingredient for conviction under Section 302 IPC.
Precedent Analysis
- Pulukuri Kottaya v. King Emperor (1947 MWN CR 45) – The Privy Council held that under Section 27 of the Evidence Act, only that part of an accused’s statement leading to discovery is admissible, not the confession itself. The Supreme Court applied this rule, stating that the alleged confession of committing the offence with the recovered weapons is inadmissible.
- Manjunath v. State of Karnataka (2023 SCC OnLine SC 1421) – Followed Pulukuri Kottaya and reiterated that only “so much of the information” leading to discovery is admissible, excluding any self-incriminating statements.
- Established Jurisprudence on Reversal of Acquittal – The Court reaffirmed that interference is permissible only when the Trial Court’s findings are perverse (Chandrappa v. State of Karnataka, 2007) and that appellate courts must not substitute their view if the Trial Court’s conclusions are reasonably possible.
These precedents collectively shaped the Court’s approach in restoring the acquittal.
Court’s Reasoning
The Bench held that the entire case hinged on doubtful identification and defective investigation. It found that the Trial Court had rightly acquitted the appellants after noting inconsistencies and lack of direct evidence. The High Court, however, reversed this acquittal without demonstrating that the Trial Court’s appreciation of evidence was erroneous or perverse, which violated settled legal standards.
The Supreme Court reasoned:
“It is safer and more appropriate to rely upon the findings of the Trial Court, which has seen the demeanor of the witnesses, rather than to rely upon the findings of the First Appellate Court.”
The Court found the prosecution’s case riddled with suspicion and conjecture rather than proof. It observed that mere motive and recovery without identification cannot sustain conviction for murder.
Conclusion
The Supreme Court set aside the conviction and sentence of all three appellants, granting them the benefit of doubt. The order of acquittal passed by the Trial Court was restored. The Bench concluded:
“It is doubtful whether the offence has been committed by the appellants. The conviction is accordingly set aside, and the appellants are acquitted by extending them the benefit of doubt.”
Their bail bonds were ordered to be discharged.
Implications
This judgment reinforces the principle that acquittals cannot be reversed casually. The prosecution must conclusively establish the accused’s identity and guilt beyond reasonable doubt. It also underscores that recovery of weapons without forensic corroboration or proper identification cannot be the sole basis for conviction.
The ruling strengthens safeguards against wrongful convictions, emphasizing fidelity to due process, evidentiary rigour, and judicial restraint in appellate interference.
FAQs
1. When can a High Court reverse a Trial Court’s acquittal?
Only if the Trial Court’s findings are perverse, illogical, or against the weight of evidence. Otherwise, the presumption of innocence stands reinforced.
2. What is admissible under Section 27 of the Indian Evidence Act?
Only that portion of an accused’s statement that distinctly leads to discovery of a fact. Any confession of guilt remains inadmissible.
3. Why was the conviction set aside in this case?
Because the prosecution failed to prove the appellants’ identity beyond reasonable doubt, and no reliable eyewitness or forensic evidence supported the charge.