Delve into the case of Chandan v. State of Delhi, where the accused, Chandan, stands trial for the stabbing death of Rakesh. With the star witness, PW-2, providing a detailed account of the incident, the prosecution’s case hinges on eyewitness testimony and forensic evidence. Despite the absence of a clear motive, the compelling eyewitness testimony and swift action of law enforcement officers solidify the case against Chandan. This summary highlights the importance of circumstantial evidence in linking various aspects of the case to establish guilt.
Facts
- Star witness PW-2 saw the deceased and accused grappling, followed by the accused stabbing the deceased multiple times with a knife.
- The deceased, Rakesh, succumbed to his injuries and passed away despite efforts to save him.
- Post-mortem revealed multiple incised stab wounds on the deceased’s body, including one on the chest that was deep enough to penetrate the heart.
- The injuries were deemed sufficient to cause death due to shock and hemorrhage.
- The weapon used in the crime, a knife, was identified and produced in court as evidence.
- An FIR was lodged based on PW-2’s statement, leading to the accused Chandan being charged under Section 302 IPC.
- After examination of 18 witnesses, the case was committed to the Sessions court for trial.
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Analysis
- The recovery of the knife from the accused was doubted initially, but the matching blood on the knife with that of the deceased supported the prosecution’s case.
- Eyewitness PW-2, who is deemed reliable, testified to the incident and confirmed the accused’s guilt.
- The absence of a clear motive does not weaken the prosecution’s case when a reliable eyewitness account is present.
- Brahm Pal Singh, a Head Constable, witnessed the recovery of the knife from the accused.
- Leading cases such as Shivaji Genu Mohite v. State of Maharashtra support the weight of eyewitness testimonies.
- The eyewitness provided a detailed account of the stabbing incident, reinforcing the prosecution’s case.
- The quick succession of events – murder, arrest, and weapon recovery – suggests the accused’s involvement.
- Forensic reports and evidence confirm that the recovered knife was used in the crime.
- Motive holds importance in circumstantial evidence cases but is less significant in the presence of a direct eyewitness.
- Law enforcement officers swiftly caught the accused with bloodstained evidence after the crime occurred.
- The prosecution’s inability to discover an impelling motive does not impact the credibility of a reliable eye-witness.
- Eye-witness testimony’s credibility remains strong even without a motive established.
- Proper proof of motive can strengthen the prosecution’s case.
- Lack of motive does not render the evidence of an eye-witness untrustworthy.
- The absence of motive is inconsequential when direct evidence establishes the crime.
- Ocular testimony inspiring court confidence removes the necessity for establishing motive in prosecution.
- Reiteration of the principle across various court cases emphasizing the significance of direct evidence over motive.
- The ratio of the judgment focuses on the significance of circumstantial evidence in a case.
- It highlights how such evidence can form a crucial link in establishing guilt.
- Circumstantial evidence plays a key role in connecting various aspects of a case to reach a conclusion.
- The judgment underscores the importance of considering the chain of circumstantial evidence as a whole.
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Decision
- Copy of judgment to be sent to Trial Court for appellant to complete remaining sentence
- Interim bail granted on 09.05.2012 is vacated
- Appellant currently on bail must surrender before Trial Court within four weeks
- No interference with Trial Court and High Court orders, appeal dismissed
Also Read: Murder Case: Ram Murti Sharma v. The State of UP
Case Title: CHANDAN Vs. THE STATE (DELHI ADMN. ) (2024 INSC 271)
Case Number: Crl.A. No.-000788-000788 / 2012
