BRIEF FACTS OF THE CASE
- In a nutshell, the prosecution claims that the dead, Om Prakash, was friendly with the current appellant/accused, Ram Pratap.
- On December 13, 2007, at 10:00 a.m. The accused Ram Pratap went to the house of the dead – Om Prakash – and after tea, the two went together. At noon., the present appellant, Ram Pratap, and others arrived at the deceased’s house in a jeep with his lifeless body.
- He met with the deceased’s brother, Jagdish Chander (PW – 4), and informed him that the deceased died at his home. An FIR was launched in response to Jagdish Chander’s (PW-4) complaint. Following the conclusion of the investigation, a charge sheet was submitted against the four accused individuals.
- In terms of Jagdish Chander’s (PW – 4) evidence, when he reported the matter to the police based on which an FIR was filed, he just voiced suspicion towards the current appellant. We also discovered that there was a 14-hour delay in reporting the event to the police.
- The learned trial Court, relying on the evidence of PW-4, PW-7, and PW-8, concluded that the prosecution had established the case against the current appellant beyond a reasonable doubt. Furthermore, the Trial Judge acquitted the other accused based on the same evidence, and the High Court supported that acquittal.
- The High Court relied on Jagdish Chander’s testimony in upholding the appellant’s conviction (PW-4).
- Furthermore, the High Court particularly notes that Bhagwan (PW-5), the deceased’s brother-in-law and the witness to the last scene, has turned hostile and hence does not support the prosecution case.
LEGAL ISSUE
Whether the High Court and the trial court were both justified in convicting the appellant?
OBSERVATION BY THE COURT
Ram Pratap was one of the suspects in the murder case. The Trial Court convicted him under Section 302 of the Indian Penal Code, and the Punjab and Haryana High Court maintained the conviction.
The Supreme Court emphasized in its decision that the case is based on speculative evidence. It was argued on behalf of the appellant-accused that there is no proof worthy of the name.
The panel cited Sharad Birdhichand Sarda v. State of Maharashtra, reported at (1984) 4 SCC 116, which stated that suspicion, no matter how strong, cannot substitute for proof beyond a reasonable doubt. It went on to say:
“This Court has ruled that there is a grammatical as well as a legal distinction between may and must. To prove a case based on circumstantial evidence, the prosecution must establish every circumstance beyond a reasonable doubt, and the circumstances so proved must form a complete chain of evidence so as not to leave any reasonable ground for the conclusion consistent with the accused’s innocence, and must show, in all human probability, that the act was committed by the accused… Furthermore, it has been maintained that the evidence as shown must rule out all hypotheses but the accused’s guilt.”
The court also stated that the 14-hour delay in filing the oral report was not well explained. Taking into account the facts presented, the bench granted the appeal and acquitted the accused.
RATIO DECIDENDI :
While overturning a concurrent conviction of the murder suspect, the Supreme Court emphasized that suspicion—no matter how strong—cannot serve as proof beyond a reasonable doubt.
JUDGEMENT
The appeal is allowed and the appellant is acquitted of the charges. The bail bonds stand canceled.