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1974 (8) TMI 131 - SC - Indian Laws

Issues:
Conviction under Section 302 and Section 201 of the Indian Penal Code, evidence of extra judicial confessions, recovery of dead bodies, sufficiency of circumstantial evidence, appraisement of evidence by the High Court.

Analysis:
The judgment involves the conviction of four individuals for triple murder and subsequent acquittal by the Punjab and Haryana High Court. The deceased individuals were brothers of one of the accused, and the motive for the murders was alleged to be gaining a share of joint land. The prosecution's case relied on circumstantial evidence, including extra judicial confessions and the recovery of dead bodies. The trial court convicted the accused based on the motive, confessions, and recovery of bodies, but the High Court acquitted them due to lack of evidence linking the recovered bodies to the deceased and uncertainty about the homicidal nature of the deaths.

The Supreme Court, in its analysis, noted the absence of direct eyewitnesses and the reliance on circumstantial evidence for the conviction. The Court observed that the evidence presented was unsatisfactory and suffered from various infirmities. The recovery of dead bodies lacked concrete identification, as the bodies were decomposed and unrecognizable. The medical evidence did not establish a clear cause of death, casting doubt on the homicidal nature of the deaths. The Court emphasized the prosecution's burden to prove guilt beyond a reasonable doubt, highlighting the gaps and deficiencies in the evidence presented.

Regarding the extra judicial confessions, the Court found them improbable and lacking credibility. The confessions made to witnesses seemed inconsistent with the secretive nature of the murders, raising doubts about their authenticity. The Court questioned the sudden willingness of the accused to confess to individuals with no significant connection, further undermining the reliability of the confessions. The evidence of the witness who claimed to have seen one of the accused with a victim was also deemed unreliable due to the delayed reporting to the police, diminishing its probative value.

The Court emphasized that suspicion alone is insufficient to establish guilt and that proof beyond a reasonable doubt is necessary for a conviction. The involvement of multiple individuals in the crime added complexity to the case, making it challenging to determine the actual perpetrators. Ultimately, the Court upheld the High Court's acquittal, stating that unless there was a glaring infirmity in the appraisal of evidence, the Supreme Court would not interfere with the High Court's decision. The appeal was dismissed, affirming the acquittal of the accused based on the insufficiency and unreliability of the evidence presented.

 

 

 

 

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