In an Important ruling, the Supreme Court of India reaffirmed the principle that reasonable doubt must be based on substantive evidence and not mere speculation, as it upheld the convictions of Goverdhan and Rajendra in a 2001 murder case. The bench, comprising Justice B.R. Gavai, Justice K.V. Viswanathan, and Justice Nongmeikapam Kotiswar Singh, emphasized the balance between protecting the rights of the accused and ensuring justice for victims.
Background of the Case
On the morning of September 23, 2001, Suraj Sharma was brutally attacked near his residence in Shikshak Colony, Raipur, Chhattisgarh. The accused—Goverdhan, Rajendra, and their father, Chintaram—allegedly assaulted Suraj with weapons, including an axe and an iron pipe, while also delivering blows with fists and kicks. Suraj succumbed to his injuries two days later.
The Second Additional Sessions Judge, Raipur, convicted all three accused in 2002 under Section 302 read with Section 34 of the Indian Penal Code (IPC), sentencing them to life imprisonment. In 2009, the High Court of Chhattisgarh upheld the convictions of Goverdhan and Rajendra but acquitted their father, Chintaram, citing insufficient evidence of his direct involvement.
Supreme Court’s Analysis and Observations
The appeal before the Supreme Court primarily challenged the reliability of witness testimonies and raised doubts about the prosecution’s ability to establish guilt beyond reasonable doubt.
Justice Nongmeikapam Kotiswar Singh, authoring the judgment for the bench, made pivotal observations:
“The requirement of law in criminal trials is not to prove the case beyond all doubt but beyond reasonable doubt. This doubt must be actual, not trivial or based on mere possibilities. Speculative doubts cannot defeat clear evidence and logical conclusions.”
The court upheld the testimony of Lata Bai, the victim’s mother, as credible despite minor contradictions. It noted that she was a natural witness whose presence at the scene was corroborated by other evidence, including the proximity of the crime to her house.
The court observed that while several witnesses turned hostile during the trial, their initial statements corroborated critical elements of the prosecution’s case. Hostility, it said, does not render the entire prosecution case unreliable.
The court rejected the plea for parity, noting that the father, Chintaram, was acquitted based on insufficient evidence of direct involvement, whereas Goverdhan and Rajendra’s active roles in the crime were established beyond reasonable doubt.
Final Ruling
The Supreme Court dismissed the appeals and affirmed the life sentences handed to Goverdhan and Rajendra. The bench highlighted that the prosecution successfully demonstrated their involvement in the crime through a combination of direct eyewitness testimony and corroborating evidence.
In a powerful remark, the court stated, “Justice must not be compromised by vague apprehensions or fanciful doubts. Reasonable doubt must stem from substantive contradictions or gaps in evidence, not from conjecture.”
The bench also emphasized the broader implications of allowing guilty individuals to escape justice, cautioning against overreliance on speculative doubt. “The principle of reasonable doubt is a safeguard against wrongful convictions, not a tool to defeat justice,” the court remarked.
