In a landmark judgment, the Supreme Court of India acquitted seven individuals accused in the 1985 abduction and murder case of Neelam, underscoring that mere motive is insufficient to sustain a conviction in the absence of a complete chain of evidence. The bench, comprising Justice Satish Chandra Sharma and Justice Bela M. Trivedi, set aside the judgments of the Patna High Court and the trial court, which had earlier convicted the accused under sections 302 and 364 of the Indian Penal Code (IPC).
Case Background
On the night of August 30, 1985, Neelam, the wife of Ashok Kumar, was abducted from her family residence in Simaltalla, Bihar. According to the prosecution, seven accused, including Vijay Singh alias Vijay Kumar Sharma, Krishna Nandan Singh, Ram Nandan Singh, Raj Nandan Singh, Shyam Nandan Singh, Bhagwan Singh, and Tanik Singh, along with several others, forcibly entered the house, abducted Neelam, and later murdered her. The case, initiated by Neelam’s brother-in-law, Ramanand Singh (PW18), alleged that the crime was motivated by a property dispute related to Neelam’s late father, Jang Bahadur Singh.
Legal Proceedings and Convictions
The trial court, in 1992, convicted five of the seven accused (Accused Nos. 1 to 5) for murder and abduction under Sections 302/34 and 364/34 of the IPC. Accused Nos. 6 and 7 were acquitted. However, upon appeal, the Patna High Court in 2015 reversed the acquittals of Accused Nos. 6 and 7 and convicted all seven individuals. This conviction was primarily based on the alleged motive — a property dispute between Neelam’s family and the accused over her father’s estate. The court also relied on the testimonies of eyewitnesses and circumstantial evidence to uphold the conviction.
Supreme Court’s Key Observations
Upon appeal, the Supreme Court thoroughly re-examined the evidence and concluded that the prosecution’s case was riddled with inconsistencies. The Court emphasized that a motive alone cannot form the basis for conviction without a complete and reliable chain of evidence.
– Lack of Independent Witnesses: The Court noted that several natural witnesses, who were present at the scene, were not examined, including neighbors and tenants living in the same house. Instead, the prosecution relied heavily on the testimonies of family members, who were declared interested witnesses. This cast doubt on the credibility of the evidence presented.
– Contradictory Testimonies: The Court found discrepancies in the testimonies of the prosecution’s key witnesses. Notably, PW18, the informant, made conflicting statements about the involvement of certain accused, including the sudden introduction of facts not mentioned in the initial FIR. The eyewitnesses’ presence at the scene of the crime was also called into question.
– Failure to Establish Chain of Circumstantial Evidence: The bench pointed out that while there was evidence suggesting Neelam’s death, there was no direct proof linking the accused to the murder. The Court stated that in cases relying on circumstantial evidence, the chain of evidence must be complete, leading to an inescapable conclusion of guilt. In this case, the prosecution failed to meet that standard.
– Doubt Over Time and Cause of Death: The post-mortem report further complicated the case. According to the report, Neelam’s death occurred around 5:00 PM on August 30, 1985, whereas the prosecution claimed the abduction happened at 10:00 PM. This significant gap raised doubts about the accuracy of the prosecution’s timeline.
Motive Alone Insufficient for Conviction
One of the pivotal points made by the Supreme Court was that motive, while relevant, cannot substitute for concrete evidence. The Court highlighted that even though there was a property dispute between Neelam’s family and the accused, the prosecution failed to conclusively establish that this motive led to the abduction and murder. Justice Sharma remarked, “The presence of motive, no matter how compelling, cannot fill the evidentiary gaps that undermine the foundation of a criminal case.”
Conclusion and Acquittal
The Supreme Court concluded that the convictions by the lower courts were unsustainable due to the prosecution’s failure to prove the case beyond a reasonable doubt. The Court emphasized that a conviction must rest on a complete chain of evidence, linking the accused to the crime without any inconsistencies or gaps. As a result, all seven accused were acquitted of all charges and ordered to be released immediately.
Case Details
– Case Name: Vijay Singh @ Vijay Kumar Sharma vs. The State of Bihar
– Criminal Appeal No: 1031 of 2015
– Bench: Justice Satish Chandra Sharma, Justice Bela M. Trivedi
– Counsels: The appellants were represented by a team of defence lawyers, while the State of Bihar was represented by its legal counsel.
