In a recent judgment passed by the Hon’ble Division Bench of the Supreme Court emphasizes the importance of evidence being consistent with the hypothesis of guilt and highlights the principles governing cases relying on circumstantial evidence, reiterating the necessity for proof beyond a reasonable doubt for a conviction.
Brief Facts:
On April 10, 2004, Shamsher Singh, the deceased, went missing after leaving his office in Kaithal, Haryana, following phone calls. His body was later found with injuries, including a knotted throat and a badly injured eye, in a field near Shergha Road. Witnesses claimed to have seen individuals, including the appellant, Pradeep Kumar, in the vicinity on the night of the incident. The prosecution relied on witness statements, including alleged sightings of the accused, a claimed extra-judicial confession, and recovered items like a blood-stained pant and sticks, linking them to the crime. Pradeep Kumar was convicted based on circumstantial evidence and sentenced to life imprisonment under Section 302 read with Section 34 of the Indian Penal Code. The case was appealed to higher courts, culminating in the Supreme Court, challenging the conviction based on discrepancies in the evidence presented by the prosecution.
Contention of Parties
They argued that witness statements, especially those of PW-11 and PW-12, who allegedly saw the accused around the time and place of the incident, formed a substantial basis for the conviction. They emphasized the extra-judicial confession made before the Ex-Sarpanch (PW-10) as significant evidence linking the accused to the crime. The prosecution highlighted the recoveries of a blood-stained pant and sticks, along with their alleged connection to the accused through forensic evidence and the blood group match with the deceased, as crucial elements supporting the guilt of the accused.
They argued that crucial witnesses, such as PW-10, PW-11, and PW-12, had provided inconsistent, contradictory, or unreliable statements, undermining their credibility. The defense emphasized the absence of direct evidence linking the accused to the crime scene and raised doubts about the recoveries, stating that the material evidence was inconclusive and did not definitively establish the guilt of the accused.They stressed that the prosecution failed to provide conclusive evidence beyond a reasonable doubt, urging the court to consider the discrepancies and inconsistencies in the prosecution's case.
Observation by the Court:
The court scrutinized the testimonies of key witnesses (PW-10, PW-11, PW-12, and PW-16) and pointed out inconsistencies, contradictions, and improbabilities in their statements. It deemed their accounts unreliable due to discrepancies in their narratives and raised doubts about the veracity of their claims. It noted that the case primarily relied on circumstantial evidence, including alleged sightings of the accused near the crime scene and the extra-judicial confession. However, the court found these pieces of evidence insufficient and unreliable to establish guilt beyond a reasonable doubt. The court highlighted material inconsistencies between the alleged recovery items (blood-stained pant and sticks) and their connections to the accused. It also noted discrepancies between the recovered items and the type of injury sustained by the deceased, casting doubt on their relevance to the case.
Decision of the Court:
Ultimately, the Supreme Court allows the criminal appeal, overturning the judgments of the High Court and the Trial Court, and acquits the appellant, Pradeep Kumar, of all charges related to the murder of Shamsher Singh. The court concluded that the prosecution had not established its case beyond a reasonable doubt.
Case Title: Pradeep Kumar Vs. State of Haryana, 2024 Latest Caselaw 22 SC
Case No.: Criminal Appeal No. 1338 of 2010
Citation: 2024 Latest Caselaw 22 SC
Coram: Hon’ble Mr. Justice B.R. Gavai, Hon’ble Mr. Justice Pamidighantam Sri Narasimha
Petitioner's Advocate: Pranab Kumar Mullick
Respondent's Advocate: Samar Vijay Singh
Read Judgement @LatestLaws.com
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