The Supreme Court of India, in Ramu Appa Mahapatar vs. State of Maharashtra (Criminal Appeal No. 608 of 2013), has overturned the conviction of Ramu Appa Mahapatar, accused of murdering his live-in partner Manda, and set him free on the ground that the prosecution failed to establish his guilt beyond a reasonable doubt. The court emphasized that mere suspicion, however strong, cannot substitute for hard evidence.
Background of the Case
The case dates back to March 21, 2003, when the appellant Ramu Appa Mahapatar was accused of murdering his partner, Manda, at their residence in Kudus village, Maharashtra. The prosecution alleged that the appellant had a quarrel with the deceased over suspicions of an illicit affair, which led him to fatally assault her with a grinding stone and a stick.
The case against Mahapatar was based primarily on extra-judicial confessions made to four prosecution witnesses: PW-1 (Ravindra Gopal Jadhav, the landlord), PW-3 (Bhagwan, the deceased’s brother), PW-4 (Chandabai, wife of PW-3), and PW-6 (Shankar, a neighbor). However, the appellant’s defense argued that the confession lacked credibility and was contradicted by crucial omissions in witness statements recorded under Section 161 of the Criminal Procedure Code (Cr.P.C.).
Legal Issues Involved
1. Evidentiary Value of Extra-Judicial Confession: The primary evidence against Mahapatar was his alleged extra-judicial confession to witnesses, which the Supreme Court held to be weak, requiring corroboration.
2. Burden of Proof in Circumstantial Evidence: The prosecution was required to establish a complete chain of events that pointed conclusively to the appellant’s guilt.
3. Contradictions in Witness Testimonies: Several contradictions and material omissions were noted in the statements of key prosecution witnesses.
4. Standard of Proof in Criminal Cases: The judgment reiterated that suspicion, however strong, cannot replace conclusive proof.
The Supreme Court’s Observations
The bench comprising Justice Abhay S. Oka and Justice Ujjal Bhuyan set aside the conviction after critically analyzing the credibility of the extra-judicial confession and the lack of corroborative evidence. The court referred to precedents, including State of Rajasthan vs. Raja Ram (2003) 8 SCC 180 and Sahadevan vs. State of Tamil Nadu (2012) 6 SCC 403, to highlight that extra-judicial confessions are a weak form of evidence that require stringent scrutiny.
In a crucial part of the judgment, the court held:
“While conviction can be based solely on circumstantial evidence, great care must be taken in evaluating such evidence. If the evidence is reasonably capable of two inferences, the one in favor of the accused must be accepted.”
The Supreme Court further noted inconsistencies in the witnesses’ depositions:
– PW-3, the deceased’s brother, himself admitted that the appellant appeared “confused” when allegedly confessing.
– There was no forensic evidence linking the appellant to the murder.
– The alleged murder weapon (grinding stone and stick) was never conclusively established to be in the possession of the accused.
– The reaction of PW-3 (brother of the deceased) to the confession was unnatural, as he did not immediately alert the police but instead accompanied the appellant back to the scene.
Final Verdict
Considering these factors, the court concluded that the prosecution failed to establish Mahapatar’s guilt beyond reasonable doubt and held:
“It would be wholly unsafe to sustain the conviction of the appellant based on such weak circumstantial evidence which lacks credibility.”
Accordingly, the conviction and sentence passed by the First Ad-hoc Additional District and Sessions Judge, Thane (Sessions Case No. 52 of 2004) and upheld by the Bombay High Court in Criminal Appeal No. 252 of 2005 were set aside. The Supreme Court ordered that the appellant be released forthwith.
