The Supreme Court of India has overturned an order by the Allahabad High Court that had remanded a 1998 double murder case for a retrial, ruling that the trial had been fair and compliant with legal provisions under Section 294 of the Code of Criminal Procedure (CrPC). The apex court held that the High Court’s decision to allow further cross-examination of witnesses was unjustified, as the defense had already admitted the genuineness of key prosecution documents.
Background of the Case
The case involves the brutal murder of a couple, Bodha Devi and Mohan Ram, who belonged to a Scheduled Caste community. The incident occurred on the night of April 21, 1998, in Chandauli, Uttar Pradesh. According to the prosecution, the accused—Radhey Shyam Lal, Pratap, Rajesh Kumar alias Pappu, and Jagannath—attacked and murdered the couple, later dumping their bodies in a well.
The First Information Report (FIR No. 27/1998) was filed on April 22, 1998, by the victims’ son, Shyam Narayan Ram. Following an investigation that included forensic evidence linking the accused to the crime scene, all four were convicted by the trial court in 2019 and sentenced to life imprisonment.
High Court’s Decision and Supreme Court Appeal
The convicted individuals challenged the trial court’s decision in the Allahabad High Court, which, in November 2023, set aside their convictions and ordered a retrial from the stage of cross-examination of a key prosecution witness (PW2). The High Court reasoned that the defense had not been given a full opportunity to challenge the authenticity of certain documents.
However, the informant, Shyam Narayan Ram, appealed this order in the Supreme Court, arguing that the High Court’s remand was unnecessary as the defense had previously admitted the genuineness of the prosecution’s documents under Section 294 CrPC, thus eliminating the need for formal proof.
Supreme Court’s Judgment
A bench comprising Justice Vikram Nath and Justice Prasanna B. Varale heard the appeal. The Court ruled that the High Court had erred in remanding the case for retrial, observing that Section 294 of the CrPC allows documents to be admitted without formal proof if their genuineness is not contested. The defense, having repeatedly accepted the prosecution’s documents, had waived the right to later challenge their authenticity.
Justice Vikram Nath, writing the judgment, stated: “Fair trial does not mean endless retrials. The defense’s repeated admission of the documents rendered further cross-examination unnecessary. The Trial Court had rightly relied upon these documents and concluded the proceedings.”
The Court further held that the High Court’s reliance on a previous Supreme Court judgment in Munna Pandey vs. State of Bihar was misplaced, as that case dealt with contradictions in witness testimonies under Section 161 CrPC, not with the admission of documents under Section 294 CrPC.
Key Legal Issues
The Supreme Court addressed two main legal issues:
1. Applicability of Section 294 CrPC: The Court reaffirmed that when the genuineness of a document is admitted by the defense, it can be used as evidence without further formal proof. In this case, the prosecution documents, including forensic reports and investigation papers, were admitted by the defense, making further cross-examination redundant.
2. Fair Trial Considerations: The Court emphasized that while ensuring a fair trial is paramount, it does not entail repeated trials without sufficient grounds. The defense had ample opportunity to challenge the prosecution’s evidence, and procedural safeguards were followed by the Trial Court.
The Supreme Court set aside the Allahabad High Court’s order for retrial and restored the convictions handed down by the trial court. It directed the convicted individuals to surrender within six weeks and allowed them to apply for suspension of sentence, which would be considered on merit.
The case is Shyam Narayan Ram vs. State of U.P. & Anr., Criminal Appeal Nos. 16282-162
