Supreme Court Acquits Accused in Murder Case Due to Lack of Evidence: Ram Pratap vs. State of Haryana (2022)

Introduction

Date of the Judgment: 1 December 2022

Citation: Not Available

Judges: B.R. Gavai, J. and Vikram Nath, J.

Can a conviction for murder stand when the evidence is primarily circumstantial and key witnesses turn hostile? The Supreme Court of India recently addressed this critical question in the case of Ram Pratap vs. State of Haryana. The court examined whether the prosecution had successfully established a chain of circumstances that unequivocally pointed to the guilt of the accused, or if the evidence presented was insufficient to overcome the presumption of innocence. This case highlights the importance of robust evidence in criminal trials, especially when relying on circumstantial evidence.

Case Background

The case revolves around the death of Om Prakash. According to the prosecution, on December 13, 2007, at 10:00 AM, the accused, Ram Pratap, visited Om Prakash’s house. After having tea, both of them left together. Later, around midnight, Ram Pratap, along with others, brought Om Prakash’s dead body to his house in a jeep. Ram Pratap informed Jagdish Chander (PW-4), the brother of the deceased, that Om Prakash had died at his house. Jagdish Chander then filed a complaint, leading to the registration of an FIR. Following the investigation, a charge sheet was filed against four accused persons, including Ram Pratap.

Timeline

Course of Proceedings

The trial court, relying on the evidence of Jagdish Chander (PW-4), PW-7, and PW-8, convicted Ram Pratap. However, the same evidence led the trial court to acquit the other accused. The High Court upheld the conviction of Ram Pratap under Section 302 of the Indian Penal Code (IPC) while maintaining the acquittal of the other accused. The High Court noted that Bhagwana (PW-5), the brother-in-law of the deceased and a witness to the last seen, turned hostile and did not support the prosecution’s case.

Legal Framework

The Supreme Court highlighted the principles governing cases based on circumstantial evidence. The court referred to the case of Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116], emphasizing that suspicion, no matter how strong, cannot replace proof beyond reasonable doubt. The court reiterated that to prove a case based on circumstantial evidence, the prosecution must establish each circumstance beyond reasonable doubt. The circumstances must form a complete chain of evidence, leaving no reasonable ground for a conclusion consistent with the innocence of the accused. The facts established must exclude every hypothesis except the guilt of the accused.

The Court also highlighted the distinction between “may” and “must”, emphasizing that the legal standard requires a “must”, not a “may” for conviction.

Arguments

Appellant’s (Ram Pratap) Arguments:

• The counsel for the appellant argued that the High Court and trial court erred in convicting the appellant as there was no evidence to support the conviction.
• The counsel argued that the evidence was not appreciated in the correct perspective.

Respondent’s (State of Haryana) Arguments:

• The counsel for the respondent argued that the trial court and the High Court had correctly appreciated the evidence and that no interference was warranted.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame any issues. However, the core issue before the court was:

• Whether the conviction of the appellant based on circumstantial evidence was justified, considering the lack of direct evidence and the inconsistencies in the prosecution’s case.

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authority:

• Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116] – This case was cited to emphasize that suspicion, however strong, cannot substitute proof beyond reasonable doubt in cases based on circumstantial evidence. The court reiterated that the prosecution must establish each circumstance beyond reasonable doubt, forming a complete chain of evidence that excludes any reasonable conclusion consistent with the innocence of the accused.

Judgment

How each authority was viewed by the Court?

• The case of Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]* was followed by the Court to emphasize the high standard of proof required in cases based on circumstantial evidence. The Court reiterated that each circumstance must be proven beyond reasonable doubt and form a complete chain of evidence that excludes any reasonable conclusion consistent with the innocence of the accused.

What weighed in the mind of the Court?

The Supreme Court’s decision to acquit Ram Pratap was primarily influenced by the lack of concrete evidence and inconsistencies in the prosecution’s case. The court emphasized that in cases based on circumstantial evidence, the prosecution must establish each circumstance beyond a reasonable doubt, forming a complete chain that excludes any possibility of the accused’s innocence. The fact that the key witness, PW-5, turned hostile significantly weakened the prosecution’s case. Additionally, the court noted the unexplained 14-hour delay in reporting the incident to the police and the fact that the trial court disbelieved the same evidence in relation to the other accused. These factors collectively led the court to conclude that the prosecution had failed to prove Ram Pratap’s guilt beyond a reasonable doubt.

Judgment

The Supreme Court found that the High Court and the trial court were not justified in convicting the appellant. The court noted that the statement of Jagdish Chander (PW-4) regarding the accused confessing to the murder was not mentioned in the initial oral report. The court also highlighted the 14-hour delay in lodging the oral report, which was not sufficiently explained. Moreover, the only witness to the last seen theory, PW-5, turned hostile. The court emphasized that the same evidence was disbelieved by the trial court in relation to the other four accused, whose acquittal was upheld by the High Court.

The court stated, “In the present case, if the evidence of Jagdish Chander (PW – 4) is to be appreciated wherein he has stated that the accused came to his house and informed him that he has killed the deceased -Om Prakash, such statement does not find any mention in the oral report.”

The court further added, “Apart from this, the delay of 14 hours in lodging the oral report has not been sufficiently explained.”

The court concluded, “In that view of the matter, we find that the High Court as well as the trial court were not justified in convicting the appellant.”

The Supreme Court allowed the appeal, acquitted the appellant of all charges, and cancelled the bail bonds.

Key Takeaways

• Circumstantial Evidence Requires a Complete Chain: In cases based on circumstantial evidence, the prosecution must establish each circumstance beyond a reasonable doubt, and these circumstances must form a complete chain that excludes any reasonable possibility of the accused’s innocence.
• Hostile Witnesses Weaken Prosecution: The prosecution’s case is significantly weakened when key witnesses turn hostile.
• Unexplained Delays Raise Doubts: Unexplained delays in reporting an incident can raise doubts about the veracity of the prosecution’s claims.
• Consistency in Evidence is Crucial: If the same evidence is disbelieved in relation to some accused, it raises questions about its credibility in relation to others.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that a conviction based on circumstantial evidence cannot be sustained if the prosecution fails to establish a complete chain of circumstances beyond a reasonable doubt. This case reinforces the principle that suspicion, however strong, cannot substitute proof. The Supreme Court reaffirmed the importance of establishing each circumstance beyond a reasonable doubt, particularly when the case rests on circumstantial evidence.

Conclusion

In Ram Pratap vs. State of Haryana, the Supreme Court acquitted the appellant, Ram Pratap, emphasizing the critical importance of establishing a complete chain of evidence beyond reasonable doubt in cases relying on circumstantial evidence. The court found that the prosecution’s case was weakened by a hostile witness, an unexplained delay in reporting the incident, and inconsistencies in the evidence. This judgment serves as a reminder that suspicion, no matter how strong, cannot replace concrete proof in criminal trials.