In a significant legal development, the High Court’s acquittal of accused individuals in a homicide case was recently overturned. The court’s decision to restore the conviction highlighted the importance of legal analysis in criminal cases. Emphasizing the need for corroborating evidence and the consideration of common intention among the accused, the court’s judgement serves as a reminder of the rigorous legal standards required in such matters.
Facts
- The High Court acquitted accused No.1 and 3 based on benefit of doubt.
- The Trial Court held all accused had common intention to kill the deceased.
- The State of Madhya Pradesh filed the present appeal against the acquittal of accused No.1 and 3.
- The incident in question involved a demand for money and meeting between accused No.4 and 3 with the victim’s brother.
- The Trial Court had originally convicted all accused under Section 302 read with Section 34 of the IPC.
- The complainant Laxminarayan filed a First Information Report against four accused for multiple offences including Sections 302, 307, 34 of IPC, and Section 3(2)(v) of the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act.
- The accused attacked the deceased Munshilal with various weapons including firearms and an axe while he was returning after urinating in Goda of Ramswaroop.
- Eye witnesses including Laxminarayan saw the entire incident where the accused surrounded and assaulted Munshilal.
- The investigation revealed that accused number 3 and 4 assaulted the deceased when he demanded money, leading to a scuffle.
- Accused Mukesh and Kallu fired from their firearms causing the death of Munshilal, who fell in the Goda of Ramswaroop.
- The Investigating Officer recorded statements of witnesses and collected medical evidence.
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Arguments
- Dr. R.K.Taneja (P.W.6) recorded a specific finding that the cause of death for appellant No.2 Brijkishore Sharma @ Kallu was homicidal.
- The death occurred due to injuries in the femoral artery and a gunshot injury in the lungs.
- The femoral artery is considered a vital organ based on the expert medical opinion presented.
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Analysis
- The High Court acquitted appellants No.1 and 3, stating contradictions in ocular and medical evidence.
- The State appealed against the acquittal of original accused No.1 and 3.
- The High Court observed that the presence of accused No.1 and 3 was doubtful due to lack of corroboration.
- The Trial Court found common intention to kill the deceased among all the accused.
- The High Court noted discrepancies between eye witness accounts and medical evidence.
- Accused No.1 and 3 were named in the FIR and witnesses identified them at the scene.
- The trial court wrongly denied benefit of doubt to appellants No.1 and 3.
- The Supreme Court precedent regarding lack of independent witnesses and medical evidence corroboration was not considered by the High Court.
- The Trial Court convicted all the accused, including accused No.1 and 3, for the offences under Section 302 read with Section 34 of the IPC.
- The High Court erred in reversing the conviction and acquitting accused No.1 and 3 based on benefit of doubt despite no material contradictions between ocular and medical evidence.
- Presence of all accused has been established, and prosecution successfully proved that all accused, including accused No.1 and 3, shared common intention.
Also Read: Legal Analysis Critique in High Court’s Quashing Order
Decision
- The present appeal is allowed.
- Respondent No.1 and 2 are to surrender within four weeks.
- The original sentence imposed by the Trial Court is restored.
- The appeal succeeds.
- The High Court’s judgement acquitting the accused is quashed.
- The Trial Court’s judgement of conviction is restored.
Case Title: THE STATE OF MADHYA PRADESH Vs. RAMJI LAL SHARMA (2022 INSC 285)
Case Number: Crl.A. No.-000293-000293 / 2022
