The Supreme Court of India, in a detailed judgment delivered by Justice C.T. Ravikumar and Justice Sudhanshu Dhulia, dismissed the appeal of the State of Madhya Pradesh against the acquittal of three accused in the 1996 murder case of Naseem Khan. The apex court emphasized that in cases where the evidence fails to establish guilt beyond reasonable doubt, the accused are entitled to the benefit of doubt.
Background of the Case
The case dates back to October 1, 1996, when Naseem Khan was allegedly attacked near the village well of Karaikheda in Madhya Pradesh. The accused, identified as Ramjan Khan, Musaf Khan (alias Musab Khan), and Habib Khan, were alleged to have inflicted fatal injuries using a sickle, axe, and stick. The trial court convicted them of murder under Section 302 read with Section 34 of the Indian Penal Code (IPC), imposing life imprisonment and a fine of Rs. 35,000. However, the Madhya Pradesh High Court overturned this conviction in 2013, citing lack of reliable evidence, which led to the present appeal by the State.
Legal Issues Involved
The core legal question before the Supreme Court was whether the High Court’s decision to acquit the accused was justified based on the evidence and whether the trial court’s conviction was sustainable. The Supreme Court focused on the principles governing appeals against acquittals, particularly emphasizing the need for evidence to be reliable and free from contradictions.
Key Observations and Decision
The Supreme Court reappraised the evidence presented during the trial and concurred with the High Court’s view that the prosecution failed to establish the guilt of the accused beyond a reasonable doubt. The court made important observations on the following issues:
1. Unreliable Witness Testimony: The trial court relied heavily on the testimonies of key witnesses, including the mother and brothers of the deceased, who were claimed to be eyewitnesses. However, the High Court found significant inconsistencies in their statements. For example, the alleged oral dying declaration made to the deceased’s mother (PW-8) was not recorded in the First Information Report (FIR) or in her initial police statements. The Supreme Court agreed with the High Court’s assessment that the absence of such critical details casts doubt on the credibility of the testimony.
2. Necessity of Corroborative Evidence: The court highlighted that in criminal trials, especially those involving the death penalty, it is imperative for witness testimonies to be corroborated by additional evidence. In this case, no corroborative evidence was provided to substantiate the alleged eyewitness accounts.
3. Principle of Benefit of Doubt: The court underscored that the benefit of doubt must be given to the accused if there are material contradictions and inconsistencies in witness testimonies. Quoting previous judgments, the bench reiterated, “Conviction could be based on the testimony of a single witness, provided his testimony is reliable and inspires confidence.” However, the evidence in this case failed to meet the threshold of reliability.
4. No Involvement of Independent Witnesses: The Supreme Court observed that despite the incident occurring in broad daylight near a village well, no independent witnesses were examined. The court noted, “The failure to bring forth independent witnesses undermines the prosecution’s case.”
5. Medical Evidence: The postmortem report confirmed multiple injuries on the body of Naseem Khan, consistent with a homicidal attack. However, the absence of a clear connection between the injuries and the accused’s actions, as claimed by the prosecution, weakened the case.
Quote from the Judgment
The Supreme Court emphasized the importance of credible evidence, stating:
“Oral dying declarations should be of such a nature as to inspire full confidence of the court in their correctness.”
The bench further noted:
“When evidence is replete with contradictions, omissions, and lacks corroboration, benefit of doubt must be extended to the accused.”
Parties Involved
– Appellant: The State of Madhya Pradesh, represented by Advocate General Varsha Mendiratta.
– Respondents: Ramjan Khan, Musaf Khan (alias Musab Khan), and Habib Khan, represented by senior advocates.
– Case Number: Criminal Appeal No. 2129 of 2014.
