DATE: 11/02/2025
BENCH: Justice BR Gavai and Justice K Vinod Chandran
FACTS:
The present case arises from a long-standing dispute between the complainant, Sindhubai (PW-1), and the accused, Rajkumar, over property and livestock-related conflicts. On 19th December 2005, Sindhubai’s brother-in-law, Shyamrao, visited her village. The next day, Rajkumar confronted and verbally abused Shyamrao and Sindhubai’s husband, Diwaru, leading to an altercation. Fearing violence, Sindhubai lodged a complaint at Tumsar Police Station. That night, a group of men, including Rajkumar, Baburao, and other accused, forcibly entered Sindhubai’s house, dragged Shyamrao outside, and brutally assaulted both him and Diwaru. Sindhubai managed to escape and later informed the village Sarpanch and Police Patil, leading to the registration of an FIR. Following an investigation, a charge sheet was filed against ten accused, and the case was committed to the Sessions Court, Bhandara. The trial court convicted all ten accused, sentencing them to life imprisonment. On appeal, the Bombay High Court acquitted six accused and upheld the convictions of Rajkumar, Baburao, and Mehatar. During the Supreme Court appeal, Baburao passed away, abating his appeal, leaving only Rajkumar and Mehatar as the remaining appellants.
ISSUES:
The issue in this case was regarding the order of conviction passed by the High Court and the legitimacy of the statements made by some of the witnesses in this case.
JUDGEMENT WITH REASONING:
The Court allowed the appeals, setting aside the conviction and sentence imposed by both the High Court and the Trial Court. It acquitted the appellants of all charges, directing that appellant Mehatar, who was on bail, shall have his bail bonds discharged. Additionally, the Court ordered the immediate release of appellant Rajkumar, provided he is not required in any other case. All pending applications, if any, were disposed of.
The Court's decision was primarily based on the lack of reliable evidence and corroboration to sustain the conviction of the appellants. It noted that the testimony of Sindhubai (PW-1) was full of omissions and contradictions. While minor inconsistencies could be overlooked given her status as a rustic villager, the High Court itself had found parts of her testimony to be unreliable. The Court observed that Sindhubai had hidden under a cot at the time of the incident and, therefore, could not have clearly identified the accused. Additionally, the prosecution failed to examine key witnesses, such as Sitabai, who could have corroborated Sindhubai’s version. Other potential witnesses, including Tekaram Rahagadale and the village Sarpanch, were also not examined, and the Police Patil (PW-4) turned hostile.
Relying on the precedent set in Vedivelu Thevar v. State of Madras, the Court reiterated that a conviction could not be based solely on the testimony of a witness found to be partly reliable unless corroborated by independent evidence. In this case, there was no corroboration to Sindhubai’s testimony, and her statements regarding the presence of certain accused and their alleged actions were deemed doubtful. Furthermore, no documentary evidence was produced to support her claim that she had previously reported threats to the police. Given these deficiencies, the Court found that the prosecution had failed to prove its case beyond a reasonable doubt. Consequently, the Court ruled that the appellants were entitled to the benefit of the doubt, set aside their conviction and sentence, and ordered their acquittal.
ANALYSIS:
The Supreme Court’s decision in this case underscores the fundamental principle of criminal jurisprudence that an accused must be convicted only if the prosecution proves its case beyond a reasonable doubt. The Court meticulously examined the reliability of the evidence presented, particularly the testimony of Sindhubai (PW-1), which was found to contain significant omissions and contradictions. It emphasized that while minor inconsistencies could be overlooked, the witness’s inability to clearly identify the accused due to her hiding under a cot created reasonable doubt regarding the veracity of her statements. Furthermore, the prosecution’s failure to present key witnesses who could have corroborated Sindhubai’s version, such as Sitabai, Tekaram Rahagadale, and the village Sarpanch, severely weakened its case. The Court also noted that the Police Patil (PW-4) turned hostile, further diminishing the credibility of the prosecution’s evidence. In the absence of independent corroboration, the Court determined that the evidence was insufficient to sustain the conviction.
By relying on the precedent set in Vedivelu Thevar v. State of Madras, the Court reaffirmed that the quality of evidence takes precedence over the quantity of witnesses. It classified Sindhubai’s testimony as partly reliable and partly unreliable, which, according to established legal principles, required corroboration. However, the absence of supporting evidence meant that a conviction based solely on her testimony would be legally untenable. The Court’s decision reflects its commitment to upholding the principles of fair trial and due process, ensuring that no individual is wrongfully convicted based on doubtful or uncorroborated testimony. By acquitting the appellants and granting them the benefit of the doubt, the Court reinforced the legal safeguard that an accused is presumed innocent until proven guilty beyond a reasonable doubt, thereby maintaining the integrity of the criminal justice system.
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