Court’s Decision
The Supreme Court reinstated the conviction and life imprisonment of two accused for the murders of a legislator and his bodyguard at a hospital in Patna, Bihar, reversing the High Court’s acquittal. The court affirmed the trial court’s findings that the killings were premeditated, rejecting the High Court’s reasoning that discounted critical eyewitness testimonies. The Supreme Court concluded that the prosecution had established guilt under Section 302 (Murder) and Section 307 (Attempt to Murder) read with Section 34 of the Indian Penal Code (IPC), 1860, beyond a reasonable doubt.
Facts of the Case
- On 13th June 1998, the incident occurred around 8:15 p.m. at the Indira Gandhi Institute of Medical Sciences (IGIMS) hospital in Patna, where the deceased, a member of the Bihar Legislative Assembly, was admitted for treatment.
- The deceased was under judicial custody and accompanied by his bodyguard, also deceased in the incident, and several supporters. Two vehicles—a Sumo car and an Ambassador car—entered the hospital premises.
- Several armed assailants, identified as the accused, exited the vehicles and opened fire, killing the legislator and his bodyguard on the spot. Another individual suffered a gunshot wound during the crossfire.
- The trial court convicted the accused based on testimonies from four key prosecution witnesses, including eyewitnesses and the deceased’s family members.
Issues
- Whether the High Court was correct in acquitting the accused based on alleged discrepancies in the testimonies of prosecution witnesses.
- Whether the testimonies of hostile and eyewitnesses could be relied upon to establish the guilt of the accused.
- Whether the prosecution sufficiently established the charge of criminal conspiracy against the accused.
Petitioner’s Arguments
- The appellant (State) argued that the High Court erred in disbelieving the prosecution’s case by highlighting minor inconsistencies, which did not go to the root of the matter.
- It was contended that the High Court unjustifiably disregarded the testimonies of key eyewitnesses, despite corroborative evidence supporting their presence and the sequence of events.
- The appellant further contended that the failure to recover weapons or establish the source of the vehicles used should not vitiate the overwhelming evidence of a premeditated attack.
Respondent’s Arguments
- The respondents argued that the High Court’s findings were justified as the prosecution had failed to provide consistent testimonies. It was also submitted that key witnesses were biased and had close affiliations with the deceased’s family.
- The respondents also pointed out the lack of corroborative evidence for the alleged conspiracy meetings held prior to the incident and the absence of clear motives for some of the accused.
Analysis of the Law
- The Supreme Court analyzed the credibility of the High Court’s findings and scrutinized the legal principles regarding the testimony of hostile witnesses. It noted that minor discrepancies in witness testimonies should not necessarily undermine the prosecution’s entire case.
- The court highlighted that the doctrine of falsus in uno, falsus in omnibus (false in one thing, false in everything) does not apply in Indian jurisprudence. Even if a witness is found to have exaggerated or erred on minor details, their testimony could still be accepted for core issues if otherwise credible.
- The court also discussed the principles of conspiracy under the IPC, noting that mere suspicion or weak circumstantial evidence cannot suffice to prove conspiracy beyond a reasonable doubt.
Precedent Analysis
- The court referenced Deep Chand & Ors. v. State of Haryana (1969) and State of U.P. v. Farid Khan (2005) to reiterate that the testimony of a hostile witness is not to be discarded entirely but should be carefully scrutinized to separate truth from falsehood.
- The judgment also cited Ponnam Chandraiah v. State of Andhra Pradesh (2008), wherein it was held that partial acceptance of a witness’s statement is permissible if the overall veracity of the testimony is intact.
Court’s Reasoning
- The court found the High Court’s approach to be overly technical, relying on discrepancies that did not impact the core of the prosecution’s case.
- The Supreme Court reasoned that the presence of the accused at the scene, corroborated by multiple independent witnesses, was sufficient to establish their participation in the crime.
- The acquittal was deemed erroneous as it discounted credible and consistent parts of the testimonies that implicated the accused.
Conclusion
- The Supreme Court restored the trial court’s conviction of two accused for murder and attempt to murder, setting aside the High Court’s order of acquittal.
- The court confirmed life imprisonment for the two accused with additional sentences under Section 307 of the IPC.
Implications
- The ruling underscores that minor inconsistencies in witness statements should not outweigh the substantial evidence of guilt, particularly in cases involving serious offenses.
- The judgment serves as a reminder to lower courts to assess evidence holistically rather than mechanically, ensuring that substantive justice is not sacrificed for procedural irregularities.