In a significant legal development, the Supreme Court of India has delivered a judgment in The Land Dispute Murder Case, resulting in the acquittal of the accused after 11 years of legal proceedings. The case involved the alleged murder of Hemwati Bai, where the prosecution failed to establish the guilt of the accused beyond a reasonable doubt. The judgment sheds light on the intricacies of criminal trials and the necessity of concrete evidence. The decision marks a crucial milestone in the justice system by emphasizing the importance of fair trials and conclusive proof.
Facts
- Appellant was sentenced to undergo life imprisonment for the murder of his stepmother.
- High Court dismissed the appeal filed by the appellant.
- Sessions Court convicted the appellant-accused under Section 302 of IPC.
- The informant, Darshu, PW-4, informed the police about Hemwati Bai’s drowning.
- No direct evidence is available, but the allegation is that the appellant assaulted the deceased on 2 March 2013, resulting in suffocation.
- Chaprasi, PW-5, the deceased’s brother, provided crucial evidence for the prosecution.
- Ten witnesses were examined by the prosecution, including Sukhmani Bai, the village officer, whose testimony supported the appellant’s extra-judicial confession.
- The appellant allegedly had a land dispute with the deceased and was seen by PW-5 dragging her by her hair towards the village pond.
- Despite PW-1 being declared hostile, the Trial Court and High Court relied on parts of her testimony where she mentioned seeing the appellant putting the deceased’s head inside the pond water.
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Arguments
- The appellant’s counsel argued that PW-1’s evidence cannot be believed as she did not originally mention the confession in her testimony.
- The defense pointed out that the incident occurred in the presence of other people near a temple, raising doubt on the isolation of the crime.
- Based on the postmortem report by PW-9, it was stated that the cause of death was drowning, casting doubt on the prosecution’s claim of a homicidal death.
- The defense emphasized the lack of evidence from other potential witnesses, like Lakhan, who was allegedly present during the incident but not examined by the prosecution.
- The State’s counsel reiterated that despite being a hostile witness, PW-1’s cross-examination revealed details of the confession by the appellant.
- It was argued that even if a witness is declared hostile, the Court can rely on specific parts of their testimony.
- Contradictions in witness testimonies, like PW-5 stating the appellant dragged the deceased while PW-2 did not support the prosecution, were highlighted.
- The guilt of the appellant has been established based on the oral testimony of two witnesses.
- The evidence presented is sufficient to conclude that the death of the deceased was homicidal.
- The testimony of PW-5 indicates that the appellant was last seen with the deceased, holding her by her hair.
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Analysis
- The absence of injury marks on the body of the deceased contradicts the prosecution’s case.
- The witness testimony given in court differs significantly from their police statement.
- The testimony of PW-1 regarding the appellant’s confession is deemed unreliable due to lack of prior acquaintance.
- Extra-judicial confession should be viewed with caution and requires independent corroboration.
- The credibility of the confession is weakened due to lack of a close relationship between the appellant and PW-1.
- The lack of injury on the deceased’s body questions the validity of the appellant dragging her to the pond.
- The presence of salt water in the trachea and lungs of the deceased is noted in PW-9’s evidence.
- In the absence of injuries, it is challenging to believe that the appellant forcibly dragged the deceased to the pond.
- Extra-judicial confession is considered weak evidence in the court.
- Corroboration with other evidence on record is advisable.
- In the absence of a chain of cogent circumstances, courts are reluctant to rely on extra-judicial confessions for the purpose of conviction.
- The case being discussed lacks additional cogent circumstances to support the extra-judicial confession.
- The statement made under Section 164 CrPC by witness Shambhu Singh (PW 3) does not include the extra-judicial confession made by the accused Babu Lal.
- No other circumstances are present on record to support the extra-judicial confession.
- Appellant’s guilt not proved beyond a reasonable doubt.
- Evidence of PW-5 of last seen together not worthy of acceptance.
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Decision
- The appellant is acquitted of the offence registered with FIR No 68 of 2013 of Police Station Kharora, district Raipur.
- The appellant shall be set at liberty unless his custody is required in any other case.
- The appeal is allowed, and the impugned judgment and order dated 7 April 2018 and 9 July 2013 are set aside.
- The appellant was incarcerated for 11 years.
Case Title: RATNU YADAV Vs. THE STATE OF CHHATTISGARH (2024 INSC 487)
Case Number: Crl.A. No.-001635-001635 – 2018
