Supreme Court acquits accused in murder case due to unreliable witness testimony: Dharambir vs. State of Haryana (2024)

Date of the Judgment: April 16, 2024

Citation: 2024 INSC 307

Judges: B.R. Gavai, J., Sandeep Mehta, J.

Can a conviction for murder be upheld when the primary eyewitness testimony is inconsistent and the extra-judicial confession is contradicted? The Supreme Court of India recently addressed this critical question in a case where the prosecution’s evidence was found to be unreliable. The Court acquitted the accused, emphasizing the importance of credible evidence in criminal trials. The judgment was authored by Justice Sandeep Mehta, with Justice B.R. Gavai concurring.

Case Background

The case revolves around the death of Karambir, who was fatally stabbed in a cinema hall in Bhiwani on June 5, 1998. The prosecution alleged that the accused, Dharambir, committed the murder due to a suspicion that Karambir was having an affair with his wife. The incident occurred at Prabhat Cinema, where Karambir was watching a movie with his brother, Krishan Kumar, and other acquaintances.

According to the prosecution, Dharambir, who was also present at the cinema, stabbed Karambir in the chest, causing his immediate death. The prosecution’s case primarily rested on the testimony of Krishan Kumar (PW-5), the deceased’s brother, and Ram Kumar (PW-8), who claimed that Dharambir made an extra-judicial confession to him.

Timeline

Course of Proceedings

The Sessions Judge, Bhiwani, convicted Dharambir under Section 302 of the Indian Penal Code, 1860, sentencing him to life imprisonment. The High Court of Punjab and Haryana at Chandigarh upheld the trial court’s decision. Dharambir then appealed to the Supreme Court of India, challenging the concurrent findings of guilt by the lower courts.

Legal Framework

The primary legal provision in this case is Section 302 of the Indian Penal Code, 1860, which deals with the punishment for murder. It states, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.” The case also involves the evaluation of witness testimony and the admissibility of extra-judicial confessions under the Code of Criminal Procedure, 1973.

Arguments

Appellant’s Arguments (Dharambir):

• The primary witness, Krishan Kumar (PW-5), made significant improvements in his testimony compared to his initial statement (Exhibit-PF).
• There were contradictions in the timings of the incident as stated by Krishan Kumar (PW-5) and Raj Kumar (PW-9), the cinema manager.
• Krishan Kumar’s (PW-5) presence at the crime scene was doubtful as he had no blood stains on his person or clothes, which would be expected if he had tried to help his brother.
• Krishan Kumar’s (PW-5) statements about seating arrangements contradicted the Investigating Officer’s (PW-11) findings.
• The prosecution failed to examine the gatekeeper, who was the first person informed about the incident, leading to an adverse inference.
• The extra-judicial confession made to Ram Kumar (PW-8) was unreliable because Ram Kumar was closely related to the deceased, and the confession was contradicted by Piare Lal (DW-1), who was present at the time of the alleged confession.
• The testimony of Krishan Kumar (PW-5) and Ram Kumar (PW-8) are unreliable, and without their evidence, there is no case against the appellant.

State’s Arguments (Haryana):

• Krishan Kumar (PW-5), being the real brother of the deceased, is a natural and trustworthy witness.
• There was no reason for Krishan Kumar (PW-5) to falsely implicate the accused, who was also a relative.
• Ram Kumar’s (PW-8) testimony about the extra-judicial confession corroborates Krishan Kumar’s (PW-5) evidence.
• The trial court and High Court’s concurrent findings of fact should not be interfered with.

[TABLE] of Submissions Categorized by Main Submissions:

Innovativeness of the Argument: The appellant’s counsel innovatively highlighted the inconsistencies and improbabilities in the prosecution’s case, particularly the lack of blood stains on the primary eyewitness and the contradictions in seating arrangements, which were not adequately addressed by the prosecution.

Issues Framed by the Supreme Court

The core issue before the Supreme Court was:

1. Whether the testimonies of Krishan Kumar (PW-5) and Ram Kumar (PW-8) were reliable enough to affirm the guilt of the accused.

Treatment of the Issue by the Court

[TABLE] Demonstrating How the Court Decided the Issues:

Authorities

Cases Relied Upon by the Court:

• Pritinder Singh Alias Lovely v. State of Punjab [(2023) 7 SCC 727] – The Supreme Court of India relied on this case to emphasize that an extra-judicial confession is a weak piece of evidence and requires strong corroboration.

Legal Provisions Considered by the Court:

• Section 302 of the Indian Penal Code, 1860 – This section defines the punishment for murder. The court considered this provision in the context of the evidence presented.

[TABLE] of Authorities Considered by the Court:

Judgment

[TABLE] How Each Submission Made by the Parties Was Treated by the Court:

How Each Authority Was Viewed by the Court:

• The Supreme Court relied on Pritinder Singh Alias Lovely v. State of Punjab [(2023) 7 SCC 727] to emphasize that an extra-judicial confession is a weak piece of evidence and requires strong corroboration, which was absent in this case.

What weighed in the mind of the Court?

The Supreme Court’s decision to acquit Dharambir was primarily driven by the unreliability of the prosecution’s key witnesses. The Court emphasized that the inconsistencies and improbabilities in Krishan Kumar’s (PW-5) testimony, along with the contradicted extra-judicial confession by Ram Kumar (PW-8), did not meet the threshold for a conviction beyond a reasonable doubt. The Court also highlighted the lack of corroborating evidence and the failure of the prosecution to examine the gatekeeper, which further weakened their case.

[TABLE] of Sentiment Analysis of Reasons Given by the Supreme Court:

Fact:Law Ratio:

The Supreme Court’s decision was primarily influenced by the factual discrepancies and inconsistencies in the evidence presented by the prosecution. The Court placed greater emphasis on the factual aspects of the case, particularly the reliability of witness testimonies, rather than solely on legal interpretations.

Logical Reasoning:

The Court considered the possibility that the accused could be guilty but emphasized that the prosecution failed to provide reliable evidence to prove guilt beyond a reasonable doubt. The Court rejected the argument that the concurrent findings of the lower courts should be upheld, as the evidence presented was found to be insufficient and unreliable.

The Supreme Court’s decision was based on the following key reasons:

• “The witness made gross improvements from his earlier statement (Exhibit -PF) based upon which, the FIR came to be registered.”
• “The very presence of Krishan Kumar (PW -5) at the crime scene is doubtful and his testimony is not trustworthy.”
• “Even otherwise, extra judicial confession by its very nature is a weak piece of evidence.”

There were no dissenting opinions in this case. Both judges on the bench agreed that the prosecution’s evidence was insufficient to sustain the conviction.

The Supreme Court’s decision highlights the importance of credible and consistent evidence in criminal trials. The judgment reinforces the principle that the prosecution must prove the guilt of the accused beyond a reasonable doubt, and mere suspicion or weak evidence is not sufficient for conviction. This case also emphasizes the caution that courts must exercise when relying on extra-judicial confessions and the need for strong corroborating evidence.

The implications of this judgment are that lower courts must thoroughly scrutinize witness testimonies and extra-judicial confessions. The ruling underscores that the benefit of doubt must be given to the accused if the prosecution fails to establish guilt beyond a reasonable doubt. This case may lead to more rigorous evaluation of evidence in similar cases.

No new doctrines or legal principles were introduced in this judgment. The Court applied existing principles of criminal law, particularly regarding the standard of proof and the evaluation of evidence.

Key Takeaways

• Eyewitness testimony must be consistent and reliable to be considered credible.
• Extra-judicial confessions are weak evidence and must be corroborated with strong, substantive evidence.
• The prosecution must prove the guilt of the accused beyond a reasonable doubt.
• The benefit of doubt must be given to the accused if the prosecution’s evidence is weak or inconsistent.
• Lower courts must thoroughly scrutinize witness testimonies and evidence before convicting an accused.

The judgment may lead to more rigorous scrutiny of witness testimonies and extra-judicial confessions in criminal trials. It reinforces the importance of credible evidence and the principle of “innocent until proven guilty.”

Directions

The Supreme Court directed that the appellant, Dharambir, be acquitted of the charge. Since he was on bail, he was not required to surrender, and his bail bonds were discharged.

Development of Law

The ratio decidendi of this case is that a conviction cannot be sustained based on unreliable witness testimony and a contradicted extra-judicial confession. This judgment reinforces the established principle that the prosecution must prove the guilt of the accused beyond a reasonable doubt. There is no change in the previous position of law, but this judgment emphasizes the strict application of existing principles regarding the standard of proof and the evaluation of evidence in criminal trials.

Conclusion

The Supreme Court of India acquitted Dharambir, emphasizing the importance of credible evidence in criminal trials. The Court found the prosecution’s evidence, primarily the testimony of Krishan Kumar (PW-5) and the extra-judicial confession to Ram Kumar (PW-8), to be unreliable. This judgment serves as a reminder of the high standard of proof required in criminal cases and the need for thorough scrutiny of evidence.

Category

Parent Category: Indian Penal Code, 1860

Child Categories:

• Section 302, Indian Penal Code, 1860
• Criminal Law
• Evidence Law
• Witness Testimony
• Extra-Judicial Confession
• Standard of Proof
• Supreme Court Judgments

FAQ

Q: What was the main issue in the Dharambir vs. State of Haryana case?

A: The main issue was whether the testimonies of the prosecution witnesses were reliable enough to uphold a murder conviction.

Q: Why did the Supreme Court acquit the accused?

A: The Supreme Court acquitted the accused because the primary eyewitness testimony was inconsistent and the extra-judicial confession was contradicted, making the prosecution’s evidence unreliable.

Q: What is an extra-judicial confession?

A: An extra-judicial confession is a confession made by an accused to someone other than a law enforcement officer or a judge. It is considered a weak piece of evidence and requires strong corroboration.

Q: What does “beyond a reasonable doubt” mean in a criminal trial?

A: “Beyond a reasonable doubt” means that the prosecution must present enough evidence to convince a reasonable person that the accused is guilty, leaving no logical doubt about their guilt.

Q: What is the significance of this judgment?

A: This judgment emphasizes the importance of credible and consistent evidence in criminal trials and reinforces that the benefit of doubt must be given to the accused if the prosecution fails to prove guilt beyond a reasonable doubt.