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Issues Involved
1. Credibility of eye-witness testimony 2. Reliability of dying declaration 3. Validity of incriminating discoveries 4. Evaluation of medical evidence regarding time of death 5. Presumption of innocence and standard of proof in criminal appeals 6. Examination of motive for the crime Issue-wise Detailed Analysis 1. Credibility of Eye-Witness Testimony The primary eye-witness, P.W. 5, Vilas, had a known quarrel with the second accused and was friendly with Sita Ram (P.W. 8), who bore hostility towards the accused. Despite potential bias, the court found his testimony credible, as it was corroborated by other witnesses and circumstances. Vilas described the sequence of events leading to the attack and identified the accused as the assailants. His account was supported by P.W. 6 and P.W. 12, who confirmed seeing Vilas and the deceased together at Bibi. 2. Reliability of Dying Declaration The dying declaration made by the deceased, Hariba, was corroborated by P.W. 2 and P.W. 9. Hariba named the accused as his assailants before he died. The court found the declaration credible, despite the non-examination of Anna, who initially drew the statement from Hariba. The court noted that P.W. 2 and P.W. 9's testimonies were consistent and credible enough to prove the dying declaration. 3. Validity of Incriminating Discoveries The court considered the discovery of a knife with human blood and the accused's clothes with blood stains as significant incriminating evidence. The second accused's clothes had blood stains matching the deceased's blood group. The first accused led to the discovery of a hunter with a lead-ball, which was not commonly found in fields or houses. These discoveries, coupled with the eye-witness testimony and dying declaration, reinforced the prosecution's case. 4. Evaluation of Medical Evidence Regarding Time of Death The court rejected the argument that the time of death was inconsistent with the prosecution's timeline based on the presence of undigested food in the deceased's stomach. The court noted that the digestive process could vary and that the presence of undigested food was not conclusive evidence of the exact time of death. The court emphasized the need for a scientific approach to medical evidence and found that the prosecution's timeline was plausible. 5. Presumption of Innocence and Standard of Proof in Criminal Appeals The court acknowledged the principle that an acquitted accused should not be convicted on appeal without substantial and compelling grounds. The court reviewed the evidence de novo and found that the High Court's judgment met the exacting standard required to overturn an acquittal. The court emphasized that reasonable doubts must operate to the advantage of the appellant but found that the prosecution had proved the guilt of the accused beyond reasonable doubt. 6. Examination of Motive for the Crime The court noted that the enmity between Sita Ram and the accused provided a plausible motive for the crime. The accused's hostility towards Hariba, a loyal dependent of Sita Ram, was evident from their actions and statements during the attack. The court found that the lack of clear evidence of motive did not undermine the otherwise sufficient evidence of guilt. Conclusion The court confirmed the conviction and life sentence of the accused, dismissing the appeal. The judgment emphasized the importance of corroborative evidence, the reliability of dying declarations, and the careful evaluation of medical and forensic evidence. The court upheld the High Court's decision, finding that the prosecution had proved the guilt of the accused beyond reasonable doubt.
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