BENCH: Justice Abhay S. Oka & Justice Ujjal Bhuyan
FACTS:
The Trial Court found the appellant guilty of an offense under Section 302 of the Indian Penal Code, 1860 (IPC), which pertains to murder. As a result, he was sentenced to life imprisonment and ordered to pay a fine of Rs 1,00,000. If he failed to pay the fine, he would have to undergo six months of rigorous imprisonment as an additional punishment. When the appellant challenged this verdict, the High Court of Kerala upheld both his conviction and sentence. The case revolves around an incident that took place on December 31, 2010, at around 11:45 AM. On that day, the appellant attacked and stabbed Ramakrishnan (the deceased) using a knife, inflicting serious injuries. As a result of these injuries, Ramakrishnan succumbed to his wounds and died.
The prosecution argued that the motive behind the attack was long-standing enmity between the appellant and the deceased. This hostility stemmed from the fact that Ramakrishnan had allegedly been involved in the murder of the appellant’s elder brother. The prosecution presented this history of revenge as the primary reason for the fatal attack. Ultimately, both the Trial Court and the High Court found the appellant guilty beyond a reasonable doubt, leading to the confirmation of his life sentence and financial penalty. The decision of the High Court led to the appeal.
ISSUES:
The main issue in this case is the reliability of the witnesses PW-4 and PW-5 and the statements provided by them.
JUDGEMENT WITH REASONING:
The judgments of the High Court of Kerala (07/09/2016) and the Trial Court, Irinjalakuda (09/10/2012) are hereby quashed and set aside. The appellant is acquitted of all charges. Having already spent over 12 years in incarceration, he is to be immediately released, provided he is not required in any other case. Accordingly, the appeal is allowed.
The Court reasoned that there were several inconsistencies and omissions in the statements of the eyewitnesses, which cast doubt on the prosecution’s case. It noted that both eyewitnesses claimed the appellant had inflicted two to three stab wounds on the deceased’s back with a knife, but these statements were found to be omissions. Additionally, PW-4’s assertion that he was standing 15 feet away from the scene of the incident was also an omission. Furthermore, PW-5’s claim that PW-4 was present at the time of the attack, along with his statement that the deceased fell on his chest, were similarly uncorroborated. The Court also found it significant that neither PW-4 nor PW-5 reported the incident to the police; instead, PW-4 stated that he had informed someone named Sumesh, who was never examined as a witness. Moreover, both witnesses failed to take the deceased to a hospital, raising further doubts about their credibility. Lastly, although other individuals were present at the time of the incident, they were not examined as witnesses, further weakening the prosecution's case.
ANALYSIS:
The case highlights the critical role of eyewitness credibility in criminal trials, particularly when the conviction hinges on their testimony. The Trial Court and the High Court of Kerala found the appellant guilty of murder based on the evidence presented by the prosecution, which emphasized a history of enmity between the appellant and the deceased. The prosecution argued that the murder was an act of revenge, stemming from the alleged involvement of the deceased in the killing of the appellant’s elder brother. However, during the appeal, the Supreme Court scrutinized the reliability of the witnesses (PW-4 and PW-5) and found significant omissions and inconsistencies in their statements. These discrepancies, including their failure to report the incident to the police, contradictions regarding their presence at the crime scene, and the absence of corroboration from other potential witnesses, raised doubts about the accuracy and trustworthiness of the prosecution’s version of events.
Given these inconsistencies, the Court determined that the prosecution had failed to establish guilt beyond a reasonable doubt, leading to the quashing of the previous convictions and the appellant’s acquittal. The ruling reinforces the principle that conviction cannot rest solely on unverified and contradictory witness testimonies, especially when other available evidence could have strengthened or disproved the prosecution’s case. The judgment underscores the importance of thorough investigation, corroboration of key testimonies, and adherence to procedural fairness in criminal trials. By setting aside the conviction, the Court upheld the fundamental principle that in cases of doubt, the benefit must go to the accused, ensuring that justice is not compromised by weak or unreliable evidence.
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