In a landmark decision, the Supreme Court of India has acquitted the accused in the case of Satpal v. State of India. The judgment sets a precedent in emphasizing the need for strong evidence to prove guilt beyond reasonable doubt. This ruling addresses the complexities surrounding joint liability under Section 34 of the Indian Penal Code. Stay tuned for more insights into this significant legal case.
Facts
- Accused No.1 Satpal armed with a sickle, Accused No.2 Virender armed with a lathi, and Hawa Singh attacked the deceased
- Witnesses PW-14 and PW-15 were present at the scene and provided crucial evidence
- The appellant was convicted under Section 302 with the aid of Section 34, IPC for sharing the common intention to murder the deceased
- Hawa Singh had a motive to commit the murder due to a property dispute with the deceased
- The first information report was lodged in the morning of 07.11.1999
- The appellant was released on bail in 2010
- Jugal Kishore, uncle of the first informant, also witnessed the incident
- Appeal questions the judgment passed by the High Court convicting the appellant along with two other accused
- The prosecution’s case details the events of the night of the incident and the actions of the accused
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Issue
- The main issue is whether the appellant participated in the offense.
- The appellant is not shown to be a friend or relative of the other accused.
- There is no specific motive presented for the appellant to murder the deceased.
Analysis
- The evidence suggests that the appellant may not have had a specific motive or direct involvement in the offense.
- Injuries sustained by the deceased point towards the use of sharp weapons by the other two accused.
- The prosecution failed to prove the active participation of the appellant in the offense beyond reasonable doubt.
- The principle of joint liability under Section 34 requires proof that the criminal act was done in furtherance of common intention of all accused.
- The injuries possibly attributed to the appellant could have been caused by the deceased falling to the ground.
- The death was primarily caused by incised injuries consistent with the use of an axe and sickle.
- Lack of strong evidence of the appellant’s active involvement in the murder.
- Common intention denotes action in concert and a prior meeting of minds.
- Acts may vary in character but are all actuated by the same common intention.
- Prior concert in the sense of a distinct previous plan is not necessary to be proved.
- Common intention to bring about a particular result may develop on the spot among multiple persons.
- Prosecution failed to prove any common intention on the appellant’s part
- No motive or reason presented for appellant’s participation in the murder
- Courts relied on assumptions and conjectures rather than reliable evidence
- Appellant has already served more than five years of imprisonment
- Evidence against the appellant is shaky and insufficient to prove guilt beyond reasonable doubt
- Benefit of doubt must enure to the appellant
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Decision
- Judgment of conviction passed by Trial Court and confirmed by High Court against appellant is set aside.
- Appellant need not be arrested as he is already on bail.
- Appeal is allowed.
- Bail bonds, if any, executed by appellant are discharged.
- Appellant is acquitted from charges levelled against him.
Case Title: VIRENDER Vs. STATE OF HARYANA
Case Number: Crl.A. No.-001339-001339 / 2010
