The Supreme Court of India has overturned the conviction of George, accused in a 2015 murder case, citing a lack of concrete evidence and emphasizing that convictions cannot be based on conjectures and surmises. The judgment, delivered by a Bench comprising Justice B.R. Gavai and Justice K.V. Viswanathan, highlighted inconsistencies in the evidence and called for greater scrutiny of the testimony of interested witnesses.
Case Background
The case originated with an FIR (No. 224 of 2015) filed by Kovilraj, the father of the deceased, Praveen Kumar, on May 16, 2015, at the Sathankulam Police Station in Tamil Nadu. The incident occurred during a festival at Immanuel Church, Ananthapuram. The prosecution alleged that the accused, George, along with two co-accused, had engaged in a heated argument with the victim before fatally attacking him with a knife.
The trial court found George guilty under Sections 294(b), 341, 302, and 506(ii) of the Indian Penal Code (IPC), sentencing him to life imprisonment. The Madurai Bench of the Madras High Court upheld this verdict, albeit acquitting the other two co-accused.
Key Legal Issues
1. Reliability of Witness Testimony: The primary evidence came from Kovilraj (PW-1), the father of the deceased and an interested witness. The High Court had questioned the reliability of PW-1’s account concerning the other two accused but upheld George’s conviction on the same testimony.
2. Standard of Evidence for Conviction: The Court examined whether a conviction could rest solely on the testimony of an interested witness, especially when other co-accused were acquitted on the grounds of insufficient evidence.
3. Recovery of Evidence: The knife allegedly used in the crime was recovered from an open area accessible to the public, raising questions about the evidentiary value of the recovery.
Observations by the Supreme Court
The Bench expressed serious concerns about the inconsistencies in the High Court’s findings, observing:
– Inconsistency in Evaluation:
“When the High Court comes to a conclusion that it is difficult to believe that PW-1 could have witnessed the incident in the manner narrated by him and grants benefit of doubt to accused Nos. 2 and 3, the conviction of accused No. 1 on the same evidence is not permissible.”
– Caution with Interested Witnesses:
“The testimony of an interested witness must be scrutinized with greater caution and circumspection.”
– Insufficiency of Recovery Evidence:
The Court dismissed the recovery of the knife as unreliable, noting that it was made from an open area accessible to all.
Judgment
The Supreme Court allowed the appeal, acquitting George of all charges and ordering his immediate release unless required in connection with any other case. The Court noted that the conviction had been based on weak evidence and reiterated the principle that every accused is entitled to the benefit of doubt.
Representation
– Appellant (George): Represented by Senior Advocate Shri S. Nagamuthu.
– State of Tamil Nadu: Represented by Senior Advocate Shri N.R. Elango.
