Delve into a recent court decision that sets a new precedent in legal analysis, focusing on the critical examination of witness testimonies and FIR discrepancies. The court’s in-depth scrutiny of minor contradictions and the weightage assigned to key evidence showcases a meticulous approach to upholding justice and legal integrity. This case summary highlights the significance of legal reasoning and the impact of thorough judicial scrutiny in ensuring fairness and accuracy in legal proceedings.
Facts
- Accused did not present any evidence in support of their defence.
- Accused Nos. 1 to 3 were found guilty and sentenced to life imprisonment for offences under Sections 148 & 302 IPC.
- Accused Nos. 4 to 11 were acquitted of all charges.
- The High Court confirmed the acquittal of Accused Nos. 4 to 11.
- Accused Nos. 1 to 3 appealed the trial court’s decision to the High Court.
- Complainant also appealed against the acquittal of Accused Nos. 4 to 11.
- High Court acquitted Accused Nos. 1 to 3 and dismissed the appeal against the acquittal of Accused Nos. 4 to 11.
- Accused Nos. 9 & 11 hacked the driver Rajesh causing bleeding injuries
- Accused Nos. 4 to 7 chased and caused injuries to fleeing witnesses
- Incident took place on 18.01.2007 near Dr. Kabir Clinic in Gayithri Estate, Kurnool
- Statements of concerned persons and witnesses recorded during investigation
- State has filed appeals against acquittal of Accused Nos. 1 to 3
- Case transferred to District & Sessions Judge’s Court for trial
- Seventeen witnesses examined by prosecution, including injured eye witnesses
- Arrest of all accused during investigation
- Complainant and State filed appeals against acquittals
- Chargesheet filed against all accused under various sections of IPC
- Accused pleaded not guilty and statements recorded under Section 313 Cr.P.C.
Also Read: Ruling on Circumstantial Evidence in Murder Case
Arguments
- The High Court did not properly consider the fact that the FIR was sent to the Magistrate within 24 hours as required by law.
- The prosecution proved the case against Accused Nos. 1 to 3 through relevant witnesses.
- The High Court doubted the FIR lodged by PW1 due to alleged interpolation of time and a delay in lodging the FIR.
- PW1 & PW3 are eyewitnesses, while PW6 & PW7 are injured eyewitnesses with consistent testimony.
- The High Court disbelieved PW1 & PW3 due to minor contradictions, but being related to the deceased or being a driver does not make them interested witnesses.
- The High Court did not reappreciate the evidence of PW5, even though the trial Court held him as a planted witness.
- The High Court should have reevaluated the entire evidence, including PW5’s testimony.
- The High Court raised an issue not framed by the trial Court regarding the FIR interpolation, which was not raised by the accused as well.
- Medical evidence supported the injuries of PW6 & PW7, making their credibility unquestionable.
- The State vehemently opposes the High Court’s acquittal of Accused Nos. 1 to 3, arguing it is not sustainable.
- The interpolation in the FIR regarding the time of lodging should not have been given undue weightage.
- The prosecution established the presence and specific roles of Accused Nos. 4 to 11, making their acquittal by the trial Court and High Court questionable.
- The High Court doubted the credibility and trustworthiness of PW1, PW3, PW6 & PW7.
- Interpolation/correction in the FIR was found, where 0.30 a.m. was converted to 9:30 p.m.
- Delay of seven hours in sending the FIR to the learned Magistrate was noted.
- High Court rightly disbelieved the FIR given by PW1 citing possibilities of false implication of the accused.
- Case heavily relies on testimony of PW1, PW3, PW5, PW6 & PW7.
Also Read: Challenging Legal Presumptions in Negotiable Instrument Cases
Analysis
- The High Court unnecessarily gave weightage to minor contradictions in the witnesses’ testimonies.
- Witnesses PW1, PW3 & PW5 were deemed as planted witnesses solely based on their relation to the deceased.
- The FIR was sent to the Magistrate within 24 hours as required by law.
- The deposition of PWs 1, 3, and 6 was consistent and supported the prosecution’s case.
- Minor contradictions in the witnesses’ testimonies were deemed not material enough to affect the prosecution’s case.
- The High Court’s observation on the timing of the FIR registration and the delay was found not fatal to the prosecution’s case.
- Identification of the assailants was done by eye-witnesses/injured eye-witnesses, not by PW7 who could not identify them.
- Roles attributed to Accused Nos. 1-3 and 4-11 were considered different, with 1-3 being main assailants.
- The High Court’s view acquitting Accused Nos. 4-11 was deemed plausible and not required to be interfered with.
- The High Court erred in discarding the testimonies of important witnesses PW1, PW3, PW5, PW6, & PW7 without proper questioning or justification.
- The case of Accused Nos. 4 to 11 is not comparable with the case of Accused Nos. 1 to 3.
- The High Court erred in acquitting Accused Nos. 1 to 3 based on the differences in their overt acts.
- The High Court’s reversal of the trial Court’s judgment convicting Accused Nos. 1 to 3 for offenses under Sections 148 & 302 IPC was a grave error.
Also Read: Legal Analysis Critique in High Court’s Quashing Order
Decision
- The High Court’s judgment acquitting Accused Nos. 1 to 3 is quashed and set aside.
- The trial Court’s judgment convicting Accused Nos. 1 to 3 for offenses under Sections 148 & 302 IPC is restored.
- Criminal Appeal No 72/2022 and Criminal Appeal No 74/2022 are allowed, challenging the acquittal of Accused Nos. 1 to 3.
- Accused Nos. 1 to 3 are directed to surrender within four weeks to undergo the remaining sentence.
- Criminal Appeal No 73/2022, challenging the acquittal of Accused Nos. 4 to 11, is dismissed.
Case Title: M. NAGESWARA REDDY Vs. THE STATE OF ANDHRA PRADESH (2022 INSC 266)
Case Number: Crl.A. No.-000072-000073 / 2022
