In a crucial ruling, the Punjab and Haryana High Court acquitted Jarnail Singh alias Jailu, who had been convicted of rash and negligent driving leading to a fatal road accident in 2012. Justice Kuldeep Tiwari, while delivering the judgment, emphasized that “merely surviving the accident does not prove the guilt of the truck driver,” underscoring the need for the prosecution to prove rash or negligent behaviour beyond reasonable doubt.
Background of the Case
Jarnail Singh had been driving a truck involved in a fatal accident on February 27, 2012, on the Barnala road. The accident led to the deaths of two people traveling in a Zen car. Singh was arrested and charged under Sections 279 (rash driving), 304-A (causing death by negligence), and 338 (causing grievous hurt by an act endangering life) of the Indian Penal Code (IPC).
The Judicial Magistrate Ist Class, Barnala, convicted Singh in October 2016, sentencing him to two years imprisonment under Section 304-A, six months under Section 279, and one year under Section 338. The Sessions Judge, Barnala, upheld this decision on appeal in August 2023.
Key Legal Issues
The defence, represented by Advocate A.S. Barnala, argued that there was no substantial evidence to prove Singh’s guilt. The main points of contention were:
1. Lack of Identification: The petitioner’s name was not initially included in the First Information Report (FIR), and no test identification parade was conducted during the investigation. Singh was identified for the first time by witnesses in court years after the incident, a point that the defence labelled as a weak piece of evidence.
2. Absence of Crucial Evidence: The defence pointed out that no site plan was produced by the prosecution, a critical piece of evidence in road accident cases. According to Justice Tiwari’s judgment, this omission made it difficult to prove whether Singh was driving rashly or negligently at the time of the accident.
3. Eyewitness Testimony: While two eyewitnesses testified that Singh was driving the truck in a rash manner, the defence highlighted inconsistencies, particularly with the photographs that suggested the car collided with the back of the truck, contrary to the witness accounts of a head-on collision.
4. Survivor Bias: The defence also argued that simply because Singh, the truck driver, survived the accident, while two individuals in the car perished, did not automatically imply guilt. The court supported this view, emphasizing that a fact could not be presumed without adequate proof.
Court’s Observations and Ruling
Justice Kuldeep Tiwari, in his detailed judgment, criticized the prosecution for failing to prove that the accident was a result of Singh’s rash or negligent driving. The court found merit in the defense’s arguments about the lack of key evidence, such as the site plan, which could have clarified how the accident occurred. The judge remarked that “a fact cannot be presumed, it must be proven beyond doubt,” a principle central to the court’s decision to acquit the accused.
The court also noted that the prosecution could not rely solely on the fact that Singh survived the accident. The judgment emphasized that guilt must be proven beyond reasonable doubt through substantial evidence, not mere assumptions based on the outcome of the accident.
Final Order
As a result of these findings, the court set aside the earlier convictions from the trial court and the appellate court. Singh was acquitted of all charges, including those under Sections 279, 304-A, and 338 of the IPC. The court ordered his immediate release from custody and discharged his bail and surety bonds.
Key Observations
– “Merely surviving the accident does not prove the guilt of the truck driver.”
– “A fact cannot be presumed, it must be proven beyond doubt.”
The case, titled Jarnail Singh alias Jailu v. State of Punjab (CRR-214-2024), had been closely watched, especially given the seriousness of the charges and the fatal outcome of the accident. However, the High Court’s ruling underscores the importance of adhering to legal standards of proof in criminal cases.
