Court’s Decision
The Supreme Court dismissed the appeals challenging the conviction of multiple accused persons for the murder of two individuals and the infliction of injuries on several others during a violent confrontation arising out of a long-standing land dispute. The Trial Court had convicted the accused under various provisions concerning unlawful assembly, common object, murder, and causing hurt. The High Court affirmed the conviction, and the Supreme Court now upheld both concurrent findings.
The Court held that the prosecution’s case was firmly established through trustworthy eyewitness testimony, medical evidence consistent with the nature of weapons used, and the common object shared by the assembly. It rejected the defence plea that the accused acted in private defence or that the prosecution suppressed the genesis of the incident. The Court found that the presence of multiple injured eyewitnesses made it improbable that the prosecution story was fabricated. The appeals were therefore dismissed.
Facts
The case involved a prolonged dispute between two families over agricultural land, boundaries, and rights of passage. On the day of the occurrence, the victims were working near the fields when a group of individuals, allegedly armed with sharp-edged weapons and sticks, confronted them. A sudden confrontation escalated into a brutal attack in which two persons sustained fatal injuries, while others received multiple wounds.
The prosecution relied on the testimony of several eyewitnesses, including injured persons who asserted that the accused had arrived armed, surrounded the victims, and inflicted repeated blows. The medical reports confirmed deep incised injuries, fractures, and blunt force trauma consistent with the weapons described.
Two persons died at the scene or shortly thereafter, while others survived with serious injuries. The police investigation led to the filing of a chargesheet against the accused for murder, attempt to murder, and unlawful assembly. The Trial Court accepted the prosecution’s case and convicted them. The High Court upheld the conviction. The accused then approached the Supreme Court.
Issues
- Whether the prosecution established beyond reasonable doubt that the accused formed an unlawful assembly with the common object of causing death.
- Whether the testimonies of injured eyewitnesses were credible and consistent.
- Whether the medical evidence corroborated the prosecution’s narrative.
- Whether the defence of private defence or mutual fight was sustainable.
- Whether the High Court erred in affirming the Trial Court’s findings.
- Whether the Supreme Court ought to interfere with concurrent findings of fact.
Petitioner’s Arguments
The appellants contended that the prosecution had suppressed the true origin of the dispute and that the complainant side were the aggressors. They alleged that the incident occurred during a spontaneous fight over farmland boundaries and that both sides sustained injuries. The appellants argued that the prosecution witnesses were partisan, belonging to the rival faction, and their testimonies contained contradictions.
The defence further submitted that the medical evidence did not conclusively establish the role of each accused, and that the attribution of specific acts was unclear. It was also argued that the number of injuries did not match the prosecution narrative and that the benefit of doubt should be extended. The appellants urged that the incident, at best, amounted to culpable homicide or a clash without premeditation.
Respondent’s Arguments
The State argued that the prosecution case rested on unimpeachable injured eyewitnesses whose presence at the scene was unquestionable. Their testimonies were consistent, independent, and corroborated by medical evidence. The State contended that the accused arrived armed, clearly demonstrating premeditation, and deliberately caused fatal injuries on vital parts of the body.
It was submitted that the sheer number of accused, their coordinated actions, and the nature of injuries inflicted showed a shared common object. The State highlighted that concurrent findings of two courts deserved respect, and the Supreme Court should not re-appreciate evidence unless the findings were perverse, which they were not. The respondent emphasized that multiple witnesses consistently implicated the accused, making the defence theory untenable.
Analysis of the Law
The Supreme Court reiterated the limits of its jurisdiction under Article 136, emphasising that it will interfere in concurrent findings only when they are perverse or unreasonable. The Court noted that:
- Eyewitness testimony, particularly of injured persons, carries high evidentiary value.
- Minor discrepancies do not vitiate otherwise credible testimony.
- Medical evidence must be consistent with the ocular version but need not be perfect in every detail.
- When multiple accused share a common object, individual overt acts need not be proved.
The medical reports in the case confirmed deep cuts, fractures, and internal injuries consistent with sharp weapons and sticks. This matched the eyewitness accounts. The Court concluded that the prosecution met its burden and that the defence failed to show alternative explanations believable enough to create reasonable doubt.
Precedent Analysis
Kathi Bharat
Reaffirmed the high evidentiary weight of injured eyewitnesses. The Court applied this principle to hold that the injured witnesses here were natural, reliable, and consistent.
Virendra Singh
Explained that common object can be inferred from conduct and nature of injuries. This principle supported the finding that the accused acted collectively.
State of Himachal Pradesh v. Mast Ram
Held that minor omissions do not shake credibility if the core testimony is consistent. The Court used this to dismiss defence arguments about minor contradictions.
Gurmail Singh
Clarified that medical evidence corroborating ocular evidence strengthens the prosecution case. Relied upon to affirm consistency between wounds and alleged weapons.
Darshan Singh
Explained lawful private defence and the limits thereof. Applied to reject the defence plea of private defence.
Court’s Reasoning
The Court found the testimonies of the injured eyewitnesses credible, consistent, and corroborated by medical reports. Their presence at the scene was natural and undeniable. The defence could not establish that they were not present or that they were lying.
The Court held that the nature of injuries — deep incised wounds on vital parts — demonstrated intention to kill. The accused arrived armed, surrounded the victims, and inflicted deliberate blows, establishing common object.
The contradictions highlighted by the defence were minor and did not damage the prosecution’s core case. Medical evidence fully supported the eyewitness version. The plea of private defence was rejected because the accused were the aggressors who initiated the attack.
The Court further observed that two courts had already evaluated the evidence in detail. Their findings were based on material evidence and were neither perverse nor irrational. Thus, the Supreme Court refused to re-appreciate evidence merely to arrive at a different finding.
Conclusion
The Supreme Court upheld the conviction of the accused for murder and related offences, finding the prosecution evidence strong, consistent, and corroborated. It ruled that the attack was deliberate, coordinated, and driven by a common object arising from the long-standing land dispute. The defence theory was found baseless. The appeals were dismissed.
Implications
- Reinforces that injured eyewitness testimony is the strongest form of direct evidence.
- Confirms that common object can be inferred from conduct and weapons used.
- Clarifies that minor inconsistencies do not undermine credible testimony.
- Demonstrates judicial restraint in disturbing concurrent sentencing findings.
- Strengthens jurisprudence on unlawful assembly leading to murder.