Court’s Decision
The Supreme Court of India set aside the conviction of a woman accused under Section 302 of the Indian Penal Code for the alleged murder of a man, granting her the benefit of doubt. The Court found serious inconsistencies in the prosecution’s case, including contradictions between medical and eyewitness evidence, unexplained injuries on the deceased’s parents, and doubts about the timing and place of death. It held that these factors, coupled with potential family enmity, rendered the prosecution’s version unreliable. The appellant was acquitted and ordered to be released forthwith.
Facts
The prosecution alleged that the appellant, along with her husband, attacked the deceased with sticks near a temple following an altercation over grazing cattle in the deceased’s field. The deceased allegedly objected because the land had not been harvested, leading to a scuffle where the appellant hit him twice on the leg. She was then taken away by her son and mother-in-law but threatened to return with her husband, which she allegedly did, resulting in the victim’s death.
The post-mortem (conducted by PW-6) revealed 13 injuries, with the cause of death being acute circulatory failure and asphyxia due to regurgitation of blood, along with head injury from a hard blunt object. The prosecution placed reliance on eyewitnesses, including the deceased’s father (PW-7), neighbours (PW-1, PW-2, PW-4), and recovery of weapons.
However, several key facts emerged:
- The medical evidence suggested death occurred between 10–12 p.m. on 23 March 1999, while eyewitnesses claimed the death happened before 9 p.m.
- The deceased’s body was found in his own courtyard, not at the alleged scene near the temple.
- Unexplained incised wounds were found on the father and mother of the deceased, which could have been self-inflicted.
- PW-7 admitted to disputes with his son over partition of family property.
- The blood-stained stick recovered from the appellant was not sent for forensic examination.
Issues
- Whether the prosecution proved beyond reasonable doubt that the appellant committed the murder.
- Whether contradictions between medical and ocular evidence undermined the prosecution’s case.
- Whether unexplained injuries on the deceased’s parents and family disputes cast doubt on the credibility of eyewitness testimony.
Petitioner’s Arguments
The appellant argued that:
- The prosecution failed to establish a consistent chain of events.
- The place and time of death were uncertain, with medical evidence contradicting eyewitness accounts.
- Key prosecution witnesses were closely related to the deceased and had potential motives due to admitted family disputes.
- Injuries on the deceased’s parents, which were never explained, suggested other possible assailants.
- The recovery evidence was weak, as the alleged weapon was neither forensically examined nor linked to the fatal injuries.
Respondent’s Arguments
The State contended that:
- Multiple eyewitnesses saw the appellant and her husband fleeing the scene with sticks, corroborating the assault.
- PW-7’s testimony included statements from the deceased identifying the assailants, amounting to a dying declaration.
- The recovery of a blood-stained danda from the appellant supported the prosecution case.
- The relationship of witnesses to the deceased should not automatically discredit their testimony.
Analysis of the Law
The Court reiterated that conviction under Section 302 IPC requires proof beyond reasonable doubt, supported by credible, consistent evidence. While related witnesses are not inherently unreliable, their testimony must be carefully scrutinised when accompanied by possible enmity.
The Court stressed that contradictions between medical and ocular evidence can be fatal to the prosecution if they go to the root of the case. Here, the medical opinion on time of death and the eyewitness version were irreconcilable. Further, recovery evidence loses probative value if forensic linkage is missing.
The principle of benefit of doubt was applied, as the evidence failed to exclude other reasonable hypotheses consistent with innocence.
Precedent Analysis
- Principle on Related Witnesses – The Court acknowledged earlier rulings that related witnesses can be reliable but emphasised scrutiny when there is admitted animosity, as in this case.
- Benefit of Doubt Doctrine – Consistent with long-standing jurisprudence, where serious doubts arise from the evidence, the accused is entitled to acquittal.
Court’s Reasoning
The Court noted:
- Inconsistency between the time of death given by PW-7 (before 9 p.m.) and medical evidence (10–12 p.m.).
- The improbability of the alleged dying declaration, which was neither accepted nor considered by the lower courts.
- The body being found at a location different from the alleged scene of attack.
- Unexplained injuries on the deceased’s parents, who admitted to prior disputes with the victim.
- Lack of forensic examination of the alleged weapon.
These factors collectively made the prosecution case unreliable.
Conclusion
The conviction and sentence under Section 302 IPC were set aside. The appellant was acquitted and ordered to be released immediately, with bail bonds cancelled if she was already on bail.
Implications
This judgment reinforces the necessity of consistent, corroborated evidence in criminal trials, particularly in murder cases. It underscores that even strong suspicions cannot replace proof beyond reasonable doubt, especially when family disputes, contradictory timelines, and incomplete forensic work undermine the prosecution.
Cases Referred
The judgment referenced settled principles on related witnesses and benefit of doubt but did not specifically cite external case law in detail. It followed established Supreme Court precedent on acquittal in cases of reasonable doubt.
FAQs
1. Can a related witness’s testimony be the sole basis for conviction?
Yes, but only if it is credible, consistent, and free from suspicion of bias. Courts apply greater scrutiny when family disputes exist.
2. Does inconsistency between medical and eyewitness evidence matter?
Yes. If the contradiction is material, it can fatally weaken the prosecution’s case.
3. What happens if the alleged weapon is not forensically examined?
Its evidentiary value is significantly reduced, and it may fail to link the accused to the crime.