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1998 (2) TMI 592 - SC - Indian Laws

Issues:
Conviction under Sections 302/34 IPC, Chain of Circumstantial Evidence, Death Sentence Confirmation, Substitution of Death Sentence with Life Imprisonment

Analysis:
The judgment involves an appeal against the conviction of the appellants under Sections 302/34 IPC and the confirmation of the death sentence by the High Court. The prosecution's case was based on circumstantial evidence, and the trial court and the High Court found the chain of circumstances complete, leading to the guilt of the appellants. The appellants argued that the chain of circumstantial evidence was not sufficient for conviction. However, both courts concluded that the evidence clearly established the guilt of the appellants, leaving no reasonable ground for innocence.

The prosecution's case rested solely on circumstantial evidence as there were no eyewitnesses to the murders. The circumstances pointed towards the appellants' involvement, as they did not show any interest in the whereabouts of the deceased persons despite living with them. The police found the bodies buried in the Dhaba, with medical evidence confirming homicidal deaths caused by sharp objects. The High Court concluded that no outsider could have committed the murders and buried the bodies in the Dhaba, indicating the appellants' involvement.

The Supreme Court analyzed the circumstantial evidence and found all links in the chain of circumstances unbroken and complete, leading to the appellants' guilt. Regarding the death sentence, the Court noted that special reasons must be given for awarding death penalty, reserved for rarest of rare cases. The trial court and the High Court justified the death sentence based on the cruelty of the act and the motive to grab property. However, the Supreme Court found no evidence of a cold-blooded murder or extreme brutality, leading to the decision to substitute the death sentence with life imprisonment under Sections 302/34 IPC.

In conclusion, the Supreme Court partially allowed the appeal by setting aside the death sentence and sentencing the appellants to life imprisonment while upholding their conviction under Sections 302/34 IPC. The judgment emphasizes the importance of complete chain of circumstantial evidence for conviction and the exceptional nature required for imposing the death penalty.

 

 

 

 

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