“The minor contradictions were insufficient to discredit the entire Prosecution’s case, The Supreme Court upheld a conviction in a Murder case spanning four decades”
Case title: Ramvir @ Saket Singh vs. The State of Madhya Pradesh
Dated no.: Criminal Appeal No(s). 1258 of 2010
Order on: 16th April 2024
Quorum: Justice B.R. Gavai and Justice Sandeep Mehta
FACTS OF THE CASE
The case involves the appeal filed by Ramvir @ Saket Singh (referred to as the appellant) against the judgment dated 27th July 2007 passed by the Division Bench of the High Court of Madhya Pradesh at Gwalior. The High Court had dismissed the appellant’s appeal against the judgment and order dated 9th November 1998 passed by the Vth Upper Sessions Judge, Bhind, Madhya Pradesh (referred to as the trial Court) in Session Case No. 70 of 1987. The trial court had convicted and sentenced the appellant for the murder of Kaptan Singh and the attempted murder of Indal Singh (PW-12).
The incidents in question occurred on 10th November 1985 in village Bhajai, District Bhind, Madhya Pradesh. The appellant was tried for the murders of Kaptan Singh and Kalyan Singh in two separate incidents, and for the attempted murder of Indal Singh in the incident where Kaptan Singh was killed.
CONTENTIONS OF THE APPELLANT
The appellants, through their counsel, vehemently denied the charges, claiming that the entire prosecution case was fabricated. They argued that the fatal injuries sustained by two members of their party were not adequately explained by the prosecution witnesses, casting doubt on the reliability of the entire case.
The appellants sought to benefit from the principle of ‘benefit of doubt,’ contending that inconsistencies in the prosecution’s narrative, coupled with the acquittal of the complainant party in a related case, warranted acquittal for the appellant.
The defense counsel challenged the credibility of key prosecution witnesses, alleging bias due to their close relationship with the deceased. They argued that the testimonies lacked corroboration and should not be accepted as sole evidence.
CONTENTIONS OF THE RESPONDENTS
The prosecution vehemently contended that the case against the appellant was neither false nor fabricated. They argued that the eyewitness testimonies, particularly that of Indal Singh, provided a consistent narrative of the events leading to the crimes. The prosecution stressed that the testimonies were credible and trustworthy, backed by medical evidence and circumstantial details. The respondent refuted the appellant’s claim that the complainant party were the aggressors. They cited the outcome of a related cross-case, where members of the appellant’s party were found to be the aggressors, leading to the deaths of two individuals. This, the prosecution argued, established the pattern of violence initiated by the appellant’s side.
The prosecution highlighted the absence of injuries on the appellant despite the alleged crossfire, suggesting discrepancies in the appellant’s version of events. They argued that the evidence presented, including the testimony of witnesses and medical reports, collectively pointed towards the guilt of the appellant.
LEGAL PROVISIONS
Section 302 of the IPC prescribes the Punishment for Murder: Whoever commits murder shall be punished with death or imprisonment for life, and shall also be liable to fine.
Section 307 of the IPC prescribes Punishment for attempt to Murder: The punishment can extend up to 10 years and in case the victim is hurt, then the maximum punishment is imprisonment for life.
ISSUE –
- Whether the prosecution’s case is based on false and fabricated evidence.
- Whether the appellant can be acquitted based on the right of private defence.
- Whether the witnesses for the prosecution are reliable.
COURT’S ANALYSIS AND JUDGEMENT
The Supreme Court meticulously analyzed the evidence and submissions presented before it. It noted the convictions in the cross-case involving members of the complainant party but highlighted that the High Court had acquitted them, affirming that the accused party was the aggressor.
The Court observed the testimony of eyewitnesses, especially Indal Singh (PW-12) and Raj Kumari (PW-7), as crucial. Despite being closely related to the deceased, their credibility was upheld, given the gravity of the incident. Their consistent testimony, corroborated by medical evidence, substantiated the prosecution’s case.
Additionally, the Court dismissed trivial contradictions raised by the defense, emphasizing the reliability of the prosecution’s evidence.
The Supreme Court upheld the judgments of the trial court and the High Court, dismissing the appeal for lack of merit. It affirmed the conviction of the appellant, Ramvir @ Saket Singh, under Sections 302 and 307 IPC for the murder of Kaptan Singh and the attempted murder of Indal Singh. The Court’s thorough analysis and adherence to legal principles underscored the importance of reliable evidence in criminal proceedings.
In summary, the case exemplifies the judiciary’s commitment to justice through meticulous examination of facts and evidence, ensuring fair trial and upholding the rule of law.
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Judgement Reviewed by – Chiraag K A