In a landmark judgment, the Supreme Court of India, in Criminal Appeal Nos. 5560-5561 of 2024, has set aside the Punjab and Haryana High Court’s order convicting and sentencing three appellants for life imprisonment in a decades-old murder case. The apex court ruled that the State of Haryana must pay compensation of ₹5,00,000 to each of the three appellants who were wrongly convicted due to judicial error and failures by the Public Prosecutor.
Background of the Case
The case originates from an appeal filed by Mahabir and two other co-accused challenging the High Court’s decision dated August 27, 2024, which overturned their acquittal and convicted them under Section 302 of the Indian Penal Code (IPC). The appellants had been acquitted by the trial court but were later convicted in a revision petition filed by the original complainant in 2006.
The Supreme Court found that the High Court’s decision was based on a fundamental violation of the accused’s right to a fair trial. The revision petition was decided without proper service of notice to the accused, in the absence of their legal representation, and without compliance with the principles of natural justice.
Key Legal Issues
1. Violation of Principles of Natural Justice:
– The appellants were convicted in revision proceedings where they were not given an opportunity to be heard.
– The Public Prosecutor, instead of aiding the court in ensuring fair proceedings, actively sought capital punishment for the accused.
2. Irregular Exercise of Revisional Jurisdiction:
– The High Court exceeded its jurisdiction under Section 401 of the Criminal Procedure Code (CrPC), which explicitly prohibits converting an acquittal into a conviction in a revision proceeding.
3. Improper Handling of Witnesses and Evidence:
– The Supreme Court noted that the High Court relied on a police statement recorded under Section 161 of CrPC, rather than the oral testimony of the witness before the trial court.
– The Public Prosecutor failed in his duty to properly cross-examine hostile witnesses.
Observations of the Supreme Court
The two-judge bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan made critical observations about the role of Public Prosecutors and judicial responsibility:
– On Judicial Errors:
“Judges are human beings and at times they do commit mistakes. The sheer pressure of work at times may lead to such errors. At the same time, the defence counsel as well as the Public Prosecutor owes a duty to correct the Court if the Court is falling in some error.”
– On Public Prosecutors’ Responsibilities:
“A Public Prosecutor is not expected to show a thirst to reach the case in the conviction of the accused somehow or the other irrespective of the true facts of the case.”
– On State Accountability:
“The State Government should be asked to pay compensation to the three appellants herein. The people have a vital interest in the manner and procedure by which the Public Prosecutor is appointed and provides assistance to the Courts.”
Judgment and Final Orders
1. The Supreme Court set aside the High Court’s judgment and restored the appellants’ acquittal.
2. The State Government was directed to pay ₹5,00,000 as compensation to each of the three appellants within four weeks.
3. The court warned that failure to comply with the compensation order would result in further action against the responsible State officers.
4. The court emphasized that judicial accountability and prosecutorial fairness are fundamental to preserving the integrity of the criminal justice system.
