Home > Recent Judgements > Reasonable Doubt’ In A Criminal Case Necessitates That Doubt Must Be Free From Speculation
Jan 14, 2025
INTRODUCTION
In the case between Goverdhan & Anr. versus State of Chhattisgarh, the case pertains to an appeal against the decision of the Division Bench of the High Court of Chhattisgarh in Bilaspur, made on November 30, 2009, in Criminal Appeal No. 290/2002. The appellants were charged with murder under Section 302 read with Section 34 of the Indian Penal Code (“IPC”), after the deceased died due to severe injuries inflicted with sharp weapons. While a co-accused was acquitted on grounds of benefit of doubt, the High Court affirmed the conviction and sentence of the two appellants. The defence claimed police coercion and presented two witnesses, while the prosecution relied on fifteen witnesses, including the victim’s mother, an eyewitness, to establish guilt. The court ultimately found that while the appellants caused the death, there was insufficient evidence to prove premeditation, leading to a conviction under Section 304 IPC with a reduced sentence and a fine.
FACTS
This appeal is based on the decision and order of the Division Bench of the High Court of Chhattisgarh in Bilaspur in Criminal Appeal No. 290/2002, which was made on November 30, 2009. Co accused was acquitted on the grounds of benefit of doubt over his involvement in the crime, but the conviction and sentence of the two appellants were affirmed by the High Court. The appellants were charged with murder under Section 302 read with Section 34 of the Indian Penal Code (“IPC). It was established that the deceased, Deceased, died of homicidal causes due to severe injuries caused by sharp weapons. The defence provided two witnesses to show that the appellants were compelled to testify by the police against the mother of the dead, Petitioner, while the prosecution presented fifteen witnesses to prove the guilt of the accused.
KEY ISSUES
- Whether the High Court erred in affirming the conviction of the appellants based on the testimony of Witness?
- Whether the evidence presented by the prosecution was sufficient to establish the guilt of the appellants beyond a reasonable doubt?
- Whether the appellants’ actions constituted murder under Section 302 IPC or a lesser offense under Section 304 IPC?
JUDGMENT
After reviewing the testimony of the victim’s mother, who was also an eyewitness, the court determined that her proximity to the scene of the crime cannot be denied. Additionally, the Court cited a multitude of decisions concerning differences in eyewitness testimony. The court ruled that neither the investigating officer nor the witness had been asked about it earlier, in response to the appellant’s claim that the eyewitness account was recorded after five days. Thus, it would be premature to use such a plea in an attempt to cast doubt on her testimony. The conclusion was drawn that the officer did not intentionally do anything to implicate the accused. According to the Court’s analysis of the testimony of other witnesses, the eyewitness testimony is supported and cannot be disbelieved. Additionally, the court firmly denied the appellants’ claim that the victim’s mother was a biassed witness. In light of the foregoing, the court found that the prosecution had established, beyond a reasonable doubt, that the appellants were guilty of causing the decedent’s death. The Court did emphasise, however, that it remained unclear if the act had been premeditated or whether there had been any prior animosity. According to the court, the reason for the crime has not been proven or substantiated. Part I of Section 304 (culpable homicide not amounting to murder) of the IPC superseded Section 302 in the conviction. In doing so, it imposed a fine of Rs.50,000/- and reduced the sentence to the time already served.
OBSERVATION
The case reaffirms the notion that even while the testimony of a connected witness may be reliable, it must be evaluated in the context of the full body of evidence, and even minor inconsistencies should not automatically preclude it from consideration. Additionally, the Court emphasised the distinction between murder and culpable homicide, which does not constitute murder due to the fact that the accused had the purpose and premeditation to commit the crime. The Supreme Court concluded that the evidence did not provide sufficient evidence to indicate premeditation or a clear purpose to kill, both of which are necessary for a conviction under Section 302 of the IPC. As an alternative, the court came to the conclusion that the appellants’ actions were likely to result in death, which required them to be convicted under Section 304 of the Indian Penal Code Instead.
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