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Case title: Chandan Vs. The State (Delhi Admin.)

Case No.: Criminal Appeal No. 788 OF 2012

Decided on: 05.04.2024

Quorum: Hon’ble Justice Sudhanshu Dhulia, Hon’ble Justice Prasanna B. Varale

FACTS OF THE CASE:

The appellant, Chandan, was convicted under Section 302 of IPC for a daylight murder involving the stabbing of the deceased multiple times with a knife. The prosecution presented 18 witnesses during the trial, with PW-2 emerging as the key eyewitness who provided a detailed narrative of the events leading to the murder. Following the stabbing, the deceased was rushed to a nearby clinic and then to a hospital but succumbed to his injuries. Chandan was apprehended on the same day of the incident with the murder weapon, a blood-stained knife, in his possession, and forensic evidence confirmed the connection between the knife and the crime scene.

LEGAL PROVISIONS:

The appellant was convicted under Section 302 of the Indian Penal Code (IPC) for the offense of murder.

The legal proceedings involved the principles of criminal jurisprudence, emphasizing the importance of direct evidence from reliable eyewitnesses in establishing guilt.

The lack of motive was deemed inconsequential when direct evidence, such as ocular testimony, was sufficient to prove the crime beyond a reasonable doubt.

APPELLANTS CONTENTION:

The defense contended that the prosecution failed to establish a motive for the accused, Chandan, to commit the murder, highlighting the absence of a compelling reason for the crime. Despite the lack of a clear motive, the defense argued that the case heavily relied on the testimony of a single eyewitness, PW-2, whose credibility was questioned. The defense also raised doubts regarding the manner in which the knife was recovered from the accused, Chandan, questioning the validity of the evidence surrounding the recovery of the murder weapon. Additionally, the defense have argued that the swift sequence of events leading to the arrest of the accused and the recovery of the knife raised questions about the thoroughness of the investigation and the possibility of tampering with evidence.

RESPONDENTS CONTENTION:

The prosecution argued that the evidence, including the eyewitness testimony of PW-2, the recovery of the knife from the accused, and forensic evidence linking the knife to the crime, established the guilt of the accused beyond a reasonable doubt. The prosecution emphasized the reliability of the eyewitness account and the swift sequence of events leading to the arrest of the accused and the recovery of the murder weapon, supporting their case for conviction under Section 302 of IPC. Both the Trial Court and the Appellate Court agreed with the prosecution, holding that the evidence presented proved the case against the accused, leading to the conviction being upheld.

COURT ANALYSIS AND JUDGMENT:

The court analyzed the case where the appellant was convicted under Section 302 of IPC for a daylight murder based on the testimony of a reliable eyewitness, PW-2, who witnessed the accused stabbing the deceased multiple times. Despite the defense’s argument about the absence of a motive, the court emphasized that in cases with direct eyewitness testimony, the lack of motive does not undermine the credibility of the witness.

The court dismissed the appeal, upholding the conviction and directing the appellant to surrender within four weeks to serve the remaining sentence, highlighting the importance of direct evidence in establishing guilt beyond a reasonable doubt.

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Judgement reviewed by – Ayush Shrivastava

Click here to read the full judgement.