In a landmark ruling, the Supreme Court of India upheld the acquittal of Raghuvir Singh, who was earlier convicted of murder under Section 302 of the Indian Penal Code (IPC). The Court emphasized that the failure to name all perpetrators in the First Information Report (FIR) is unnatural and weakens the complainant’s credibility under Section 11 of the Indian Evidence Act.
Delivering the judgment in Criminal Appeal No. 1588 of 2015, a bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan dismissed the State of Uttar Pradesh’s appeal against the High Court’s decision to acquit the accused. The Court observed that the omission of co-accused names from the FIR and inconsistencies in witness testimonies created reasonable doubt, necessitating the benefit of doubt in favor of the accused.
Background of the Case
The case dates back to August 28, 2004, when Rajkumar, a transport worker, was allegedly attacked and beheaded near a tube well in Ghaziabad, Uttar Pradesh. His father, Ompal Singh, lodged an FIR the next day, accusing Raghuvir Singh and two unidentified individuals of the crime.
The prosecution claimed that long-standing animosity between the families was the motive for the murder. According to the FIR, in 1991, Raghuvir Singh had allegedly murdered the complainant’s brother, Sitaram, which led to enmity between the two families.
Trial Court Conviction and High Court Acquittal
During the trial at the Additional District and Sessions Court, Ghaziabad, the prosecution presented three eyewitnesses—the complainant (father of the deceased), his brother, and another relative—who claimed to have seen Raghuvir Singh and two others attack Rajkumar with knives, severing his head.
The trial court convicted Raghuvir Singh, sentencing him to life imprisonment based on these eyewitness testimonies. However, the Allahabad High Court, in its judgment dated February 13, 2015, overturned the conviction, citing severe inconsistencies in the prosecution’s case and lack of independent corroboration.
Dissatisfied with the High Court’s decision, the State of Uttar Pradesh filed an appeal in the Supreme Court.
Key Legal Issues Before the Supreme Court
1. Omission of Co-Accused in FIR:
– The complainant, despite claiming to have personally witnessed the murder, only named Raghuvir Singh in the FIR, failing to mention the two juvenile co-accused.
– The Supreme Court found this omission unnatural and highly suspicious, stating that such omissions are relevant under Section 11 of the Indian Evidence Act, which deals with facts that affect the probability of the case.
2. Delay in FIR Registration:
– The FIR was registered 14 hours after the alleged murder, raising serious concerns about potential fabrication.
– The Supreme Court observed that such delays must be explained satisfactorily to avoid suspicions of manipulation.
3. Credibility of Eyewitness Testimonies:
– The three main prosecution witnesses claimed to have witnessed the crime, yet they did not immediately report it to the police.
– The Court noted that their behavior was unnatural, casting serious doubts on the veracity of their statements.
4. Reliability of Defense Evidence:
– The defense produced independent witnesses, including Satpal (DW-1), near whose field the body was discovered.
– The Court held that defense evidence must be treated at par with prosecution evidence, rejecting the trial court’s casual dismissal of defense witnesses.
Observations of the Supreme Court
The Supreme Court carefully reviewed the case, analyzing both prosecution and defense arguments before concluding that the High Court was correct in acquitting the accused. The Court made the following key observations:
Failure to Name All Accused in FIR Weakens Credibility:
Referring to Ram Kumar Pandey v. State of Madhya Pradesh (AIR 1975 SC 1026), the Court stated:
“Omissions of important facts affecting the probabilities of the case are relevant under Section 11 of the Evidence Act in judging the veracity of the prosecution’s case.”
The Supreme Court ruled that the failure to name co-accused in the FIR created reasonable doubt about the complainant’s account.
Delays in Filing FIR Cast Suspicion on Prosecution:
While delays in FIR registration do not automatically invalidate a case, they must be justified with credible reasons.
In this case, no convincing explanation was provided for the 14-hour delay, leading the Court to question the authenticity of the allegations.
Credibility of Witnesses in Doubt Due to Unnatural Conduct:
The Court found it unnatural that the eyewitnesses, who allegedly saw the crime, did not take immediate action or report the incident sooner.
Such unnatural behavior, combined with inconsistencies in testimonies, led the Supreme Court to conclude that the prosecution had failed to establish guilt beyond reasonable doubt.
Defence Evidence Must Not Be Dismissed Casually:
The Supreme Court reprimanded the trial court for dismissing defense witnesses without valid reasoning.
The Court reiterated that defense witnesses deserve equal consideration and their testimonies should not be disregarded merely because they support the accused.
Verdict: Acquittal Upheld, Appeal Dismissed
Based on these findings, the Supreme Court ruled that the High Court had correctly acquitted Raghuvir Singh. The Court held:
The omission of co-accused names in the FIR was unnatural and diminished the credibility of the complainant.
The delayed FIR and inconsistent eyewitness accounts weakened the prosecution’s case.
Reasonable doubt existed, and the benefit of doubt must always favor the accused.
Accordingly, the Supreme Court dismissed the State of Uttar Pradesh’s appeal, upholding the acquittal of Raghuvir Singh.
