Supreme Court Acquits Accused in Step-Mother’s Drowning Death: Ratnu Yadav vs. State of Chhattisgarh (2024)

Introduction

Date of the Judgment: July 09, 2024
Citation: 2024 INSC 487
Judges: Abhay S. Oka, J., Rajesh Bindal, J.

Can a conviction for murder be sustained solely on the basis of an extra-judicial confession and circumstantial evidence, especially when there are inconsistencies in witness testimonies and a lack of corroborating physical evidence? The Supreme Court of India recently addressed this critical question in the case of Ratnu Yadav vs. State of Chhattisgarh, where the accused was charged with the murder of his stepmother. The Court examined the reliability of an alleged extra-judicial confession and the significance of the “last seen together” evidence in the absence of direct evidence and any injury marks on the deceased’s body. The judgment was delivered by a division bench comprising Justice Abhay S. Oka and Justice Rajesh Bindal, with Justice Abhay S. Oka authoring the opinion.

Case Background

The prosecution’s case was that Ratnu Yadav, the appellant, had a land dispute with his stepmother, Hemwati Bai. On March 2, 2013, the prosecution alleged that Ratnu assaulted Hemwati, dragged her by her hair to a village pond, and submerged her head in the water, causing her death by drowning. The First Information Report (FIR) was filed based on information from Darshu (PW-4), who stated that Hemwati Bai died due to drowning. The prosecution presented ten witnesses, relying on an alleged extra-judicial confession to Sukhmani Bai (PW-1), a village officer, and the testimony of Chaprasi (PW-5), Hemwati’s brother, who claimed to have seen Ratnu dragging Hemwati towards the pond.

Timeline

Course of Proceedings

The Sessions Court convicted the appellant under Section 302 of the Indian Penal Code, sentencing him to life imprisonment. The High Court upheld this conviction, dismissing the appellant’s appeal. The matter then reached the Supreme Court, where the appellant challenged his conviction.

Legal Framework

The primary legal provision in this case is Section 302 of the Indian Penal Code, which defines the punishment for murder. The section states:

“302. Punishment for murder.—Whoever commits murder shall be punished with death, or [imprisonment for life], and shall also be liable to fine.”

The Supreme Court also considered the principles regarding the admissibility and evidentiary value of extra-judicial confessions and the importance of corroborative evidence, as well as the rules regarding the examination of hostile witnesses under Section 145 of the Indian Evidence Act and statements recorded under Section 161 of the Code of Criminal Procedure, 1973.

Arguments

Appellant’s Arguments (Shri Shridhar Y. Chitale, Amicus Curiae):

• ✓ The death was due to drowning, and the prosecution failed to prove it was a homicidal death.
• ✓ The testimony of PW-1, who was declared hostile, is unreliable because she did not initially state that the appellant confessed to the murder. The purported confession came only during cross-examination by the public prosecutor.
• ✓ The evidence of PW-5 is also unreliable because PW-2, who was allegedly present, did not support the prosecution’s version, and another witness, Lakhan, was not examined.
• ✓ Given the proximity of the incident to a temple and other residences, the failure to examine other potential witnesses raises doubts.

Respondent’s Arguments (Shri Prashant Singh, State Counsel):

• ✓ PW-1 clearly deposed about the confessional statement made by the appellant during cross-examination.
• ✓ The evidence of a hostile witness can be relied upon partially.
• ✓ PW-5’s testimony proves that the appellant was last seen with the deceased, holding her by her hair, sufficient to establish a homicidal death.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section, but the following issues were implicitly considered:

1. Whether the extra-judicial confession made by the appellant to PW-1 is reliable and admissible as evidence.
2. Whether the evidence of PW-5 regarding the appellant being last seen with the deceased is sufficient to establish the appellant’s guilt, especially in the absence of corroborative evidence and any injury marks on the deceased’s body.
3. Whether the prosecution has proven beyond a reasonable doubt that the death of the deceased was homicidal.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The Supreme Court considered the following authorities:

Cases:

• ✓ Devi Lal v. State of Rajasthan [ (2019) 19 SCC 447 ] – The Supreme Court held that an extra-judicial confession is a weak piece of evidence and requires corroboration with other evidence.
• ✓ Gopal Sah v. State of Bihar [ (2008) 17 SCC 128 ] – This case was cited in Devi Lal v. State of Rajasthan, emphasizing that extra-judicial confessions are weak evidence and require cogent circumstances for reliance.
• ✓ Nikhil Chandra Mondal v. State of West Bengal [ (2023) 6 SCC 605 ] – The Supreme Court reiterated that extra-judicial confession is weak evidence and requires independent reliable corroboration.

Legal Provisions:

• ✓ Section 302 of the Indian Penal Code – Defines the punishment for murder.
• ✓ Section 145 of the Indian Evidence Act – Deals with cross-examination of a witness as to previous statements in writing.
• ✓ Section 161 of the Code of Criminal Procedure, 1973 – Deals with the examination of witnesses by the police.

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• ✓ Devi Lal v. State of Rajasthan [(2019) 19 SCC 447]*: The court relied on this case to emphasize that extra-judicial confessions are weak evidence and require corroboration.
• ✓ Gopal Sah v. State of Bihar [(2008) 17 SCC 128]*: The court cited this case, which was also mentioned in Devi Lal v. State of Rajasthan, to further support the principle that extra-judicial confessions are weak evidence.
• ✓ Nikhil Chandra Mondal v. State of West Bengal [(2023) 6 SCC 605]*: The court followed this case, reiterating that extra-judicial confessions are weak evidence and require independent reliable corroboration.

What weighed in the mind of the Court?

The Supreme Court’s decision to acquit the appellant was primarily influenced by the following factors:

• ✓ Inconsistencies in Witness Testimony: The court noted significant discrepancies between the examination-in-chief and cross-examination of PW-1, the witness who claimed to have heard the extra-judicial confession.
• ✓ Lack of Corroboration: The court emphasized that extra-judicial confessions are inherently weak evidence and require corroboration, which was absent in this case.
• ✓ Absence of Physical Evidence: The postmortem report revealed no injury marks on the deceased’s body, contradicting the prosecution’s claim that the appellant dragged her.
• ✓ Non-examination of Material Witnesses: The prosecution failed to examine Lakhan, a crucial witness who allegedly saw the appellant dragging the deceased, and PW-2, who was present at the scene, did not support the prosecution’s case.
• ✓ Failure to Establish Homicidal Death: The court found that the prosecution did not prove that the death was homicidal beyond a reasonable doubt. The cause of death was drowning, but it could have been accidental or suicidal.

Sentiment Analysis of Reasons Given by the Supreme Court:

Fact:Law Ratio

The court emphasized the factual inconsistencies and lack of corroborating evidence more than the legal principles.

Logical Reasoning:

The Supreme Court found the prosecution’s case to be weak due to several factors. The court noted that the extra-judicial confession was not reliable due to inconsistencies in the witness’s testimony and lack of corroboration. The court also found that the “last seen together” evidence was insufficient because it was not supported by other witnesses and contradicted by the absence of injuries on the deceased’s body. The court also noted the prosecution’s failure to examine material witnesses. The Supreme Court emphasized that the prosecution failed to prove beyond a reasonable doubt that the death was homicidal. The court observed that the cause of death was drowning, but it could have been accidental or suicidal. The court thus decided to acquit the appellant.

The Supreme Court quoted the following from the judgment:

“It is true that an extra -judicial confession is used against its maker but as a matter of caution, advisable for the court to look for a corroboration with the other evidence on record.”

“It is a settled principle of law that extra -judicial confession is a weak piece of evidence. It has been held that where an extra -judicial confession is surrounded by suspicious circumstances, its credibility becomes doubtful and it loses its importance.”

“Considering what we have held earlier, the appellant’s guilt was not proved beyond a reasonable doubt.”

Key Takeaways

• ✓ Extra-judicial confessions are considered weak evidence and require strong corroboration.
• ✓ The “last seen together” principle cannot be the sole basis for conviction, especially without corroborating evidence.
• ✓ The prosecution must prove its case beyond a reasonable doubt, and any inconsistencies in witness testimonies or lack of physical evidence can weaken the case.
• ✓ The non-examination of material witnesses can lead to adverse inferences against the prosecution.

Directions

The Supreme Court directed that the appellant be immediately set at liberty unless his custody is required in any other case.

Development of Law

The ratio decidendi of this case is that a conviction cannot be based solely on an extra-judicial confession and circumstantial evidence, especially when there are inconsistencies in witness testimonies, a lack of corroborating physical evidence, and the prosecution fails to examine material witnesses. This judgment reinforces the principle that extra-judicial confessions are weak evidence and require strong corroboration, and it emphasizes the importance of proving guilt beyond a reasonable doubt in criminal cases.

Conclusion

In Ratnu Yadav vs. State of Chhattisgarh, the Supreme Court overturned the conviction of the appellant, holding that the prosecution failed to prove his guilt beyond a reasonable doubt. The Court emphasized the weakness of extra-judicial confessions, the need for corroborating evidence, and the importance of examining all material witnesses. This judgment underscores the high standard of proof required in criminal cases and the caution that must be exercised when relying on circumstantial evidence and extra-judicial confessions.