Supreme Court acquits police officers in custodial death case: Vinod Jaswantray Vyas vs. State of Gujarat (2024)

Date of the Judgment: July 09, 2024
Citation: 2024 INSC 490
Judges: B.R. Gavai, J., Sandeep Mehta, J.
Can a conviction for custodial death stand when eyewitness accounts contradict medical evidence? The Supreme Court of India recently addressed this critical question, ultimately acquitting two police officers initially convicted for the custodial death of an accused. This judgment underscores the importance of reliable evidence in cases of alleged custodial violence. The bench comprised Justices B.R. Gavai and Sandeep Mehta, with the majority opinion authored by Justice Mehta.

Case Background

The case revolves around the death of one Jeeva, who surrendered at the Amraiwadi Police Station in Ahmedabad on June 10, 1992, in connection with a case registered against him. He was accompanied by his advocate and two sisters. The prosecution alleged that the accused, Vinod Jaswantray Vyas (A1), a Police Inspector, and Chinubhai Govindbhai Patel (A2), the Superintendent of Police, assaulted Jeeva in custody, leading to his death. Jeeva was produced before a magistrate the next day and then sent to Sabarmati Central Jail. His condition deteriorated, and he died in the hospital on June 12, 1992. Jeeva’s sister filed a complaint alleging custodial torture.

Timeline

Course of Proceedings

The trial court convicted both A1 and A2 under Section 302 of the Indian Penal Code, 1860 (IPC), sentencing them to life imprisonment. The High Court of Gujarat, in appeal, partly accepted the appeal of A1, altering the conviction to Section 304 Part I IPC and reducing the sentence to eight years rigorous imprisonment. The High Court also directed A1 to pay a compensation of Rs. 50,000 to the heirs of the deceased. A1 then appealed to the Supreme Court. During the pendency of the appeal, both A1 and A2 passed away, and their legal heirs were allowed to continue the appeal.

Legal Framework

The case primarily involves the following sections of the Indian Penal Code, 1860:

• Section 302, IPC: This section 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.”
• Section 304 Part I, IPC: This section addresses culpable homicide not amounting to murder. It states, “Whoever commits culpable homicide not amounting to murder shall be punished with imprisonment for life, or imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine, if the act by which the death is caused is done with the intention of causing death, or of causing such bodily injury as is likely to cause death.”

The legal framework also considers the principles of custodial violence and the burden of proof in criminal cases.

Arguments

Appellant’s Arguments (Vinod Jaswantray Vyas):

• Delay in Complaint: The formal complaint was filed 20 days after the incident, raising doubts about its authenticity.
• Lack of Motive: The accused had no reason to assault Jeeva, who had voluntarily surrendered.
• Selective Assault: Only Jeeva was injured, while Anna Dorai, also an accused, was spared, which is improbable if the police intended to extract confessions.
• No Complaint to Magistrate: Jeeva did not complain to the Magistrate about the assault despite having the opportunity.
• Physical Impossibility: Jeeva could not have climbed the stairs at Karanj Bhavan after sustaining such severe injuries.
• Prison Assault: The possibility of Jeeva being assaulted by co-prisoners in Sabarmati Central Jail cannot be ruled out, given the fresh nature of the injuries.
• Red Soil: Red dust on Jeeva’s clothes suggests he was injured in Sabarmati Central Jail, where the soil is red.
• Inconsistent Eyewitness Testimony: Eyewitnesses claimed both accused targeted the same body parts, which is unlikely.
• Unrealistic Police Conduct: A seasoned police officer would not use sticks to assault a victim, risking detection.

Respondent’s Arguments (State of Gujarat):

• Reliable Eyewitnesses: Selvin Prabhakar (PW-1) and Dhanlakshmi Vaiyapuri (PW-2) had no reason to falsely implicate the accused.
• Consistent Testimony: The eyewitness accounts are consistent and trustworthy.
• Fear of Retribution: Jeeva did not complain to the Magistrate due to fear of further police violence.
• Prompt Complaint: Selvin Prabhakar sent a telegram promptly after learning of Jeeva’s death.
• Influence on Investigation: No action was taken on the telegram, indicating the accused’s influence on the investigation agency.

Innovativeness of the Argument: The appellant’s argument regarding the physical impossibility of Jeeva climbing stairs after sustaining severe injuries and the possibility of assault in jail is innovative, as it directly challenges the prosecution’s narrative by using medical and circumstantial evidence.

Issues Framed by the Supreme Court

The Supreme Court considered the following key issues:

1. Whether the conviction of the accused under Section 304 Part I of the IPC is sustainable, given the inconsistencies in the evidence.
2. Whether the High Court was correct in modifying the conviction from Section 302 to Section 304 Part I of the IPC.
3. Whether the medical evidence supports the prosecution’s claim of custodial assault.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Cases:

• Lahu Kamlakar Patil and Anr. v. State of Maharashtra, (2013) 6 SCC 417: This case was cited to highlight that while witnesses may react differently under different situations, unnatural conduct can discredit their testimony. (Supreme Court of India)
• Shivasharanappa and Others v. State of Karnataka, (2013) 5 SCC 705: This case was used to emphasize that if behavior is absolutely unnatural, the testimony of a witness may not deserve credence. (Supreme Court of India)
• Narendrasinh Keshubhai Zala v. State of Gujarat, 2023(4) SCALE 478: This case was cited to reiterate that suspicion cannot replace proof and that unnatural conduct can be a ground for disbelieving a witness. (Supreme Court of India)
• Harvinder Singh alias Bachhu v. State of Himachal Pradesh, 2023 SCC OnLine SC 1347: This case was used to show that when the conduct of a witness is unnatural, their reputation takes a back seat. (Supreme Court of India)
• Chunthuram v. State of Chhattisgarh, (2020) 10 SCC 733: This case was cited to highlight that an eyewitness’s failure to report an incident or inform family members is contrary to human nature and can discredit their testimony. (Supreme Court of India)
• Sait Tarajee Khimchand and Others v. Yelamarti Satyam alias Satteyya and Others, (1972) 4 SCC 562: This case was cited to emphasize that the mere marking of an exhibit does not dispense with the proof of documents. (Supreme Court of India)
• Narbada Devi Gupta v. Birendra Kumar Jaiswal and Another, (2003) 8 SCC 745: This case was used to show that the execution of a document has to be proved by admissible evidence. (Supreme Court of India)
• Bhajan Singh alias Harbhajan Singh and Others. v. State of Haryana, (2011) 7 SCC 421: This case was cited to show that when medical evidence makes the ocular testimony improbable, it becomes a relevant factor in evaluating evidence. (Supreme Court of India)

Legal Provisions:

• Section 302, Indian Penal Code, 1860: Punishment for murder.
• Section 304 Part I, Indian Penal Code, 1860: Culpable homicide not amounting to murder.

Table of Authorities:

Judgment

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

How each authority was viewed by the Court?

• Lahu Kamlakar Patil and Anr. v. State of Maharashtra [CITATION]*: The court used this case to emphasize that while witnesses may react differently in different situations, unnatural conduct can discredit their testimony.
• Shivasharanappa and Others v. State of Karnataka [CITATION]*: The court relied on this case to highlight that if behavior is absolutely unnatural, the testimony of a witness may not deserve acceptance.
• Narendrasinh Keshubhai Zala v. State of Gujarat [CITATION]*: The court used this case to reiterate that suspicion cannot replace proof and that unnatural conduct can be a ground for disbelieving a witness.
• Harvinder Singh alias Bachhu v. State of Himachal Pradesh [CITATION]*: The court used this case to show that when the conduct of a witness is unnatural, their reputation takes a back seat.
• Chunthuram v. State of Chhattisgarh [CITATION]*: The court cited this case to emphasize that an eyewitness’s failure to report an incident or inform family members is contrary to human nature and can discredit their testimony.
• Sait Tarajee Khimchand and Others v. Yelamarti Satyam alias Satteyya and Others [CITATION]*: The court used this case to emphasize that the mere marking of an exhibit does not dispense with the proof of documents.
• Narbada Devi Gupta v. Birendra Kumar Jaiswal and Another [CITATION]*: The court relied on this case to show that the execution of a document has to be proved by admissible evidence.
• Bhajan Singh alias Harbhajan Singh and Others. v. State of Haryana [CITATION]*: The court cited this case to show that when medical evidence makes the ocular testimony improbable, it becomes a relevant factor in evaluating evidence.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the contradictions between the eyewitness accounts and the medical evidence. The court noted that the medical evidence, particularly the postmortem report and the testimony of the medical jurist, strongly suggested that the injuries were inflicted closer to the time of death, and not during the alleged custodial torture. The court also found the conduct of the eyewitnesses to be unnatural, and their testimony was not reliable. The lack of a clear motive for the accused to assault Jeeva, and the fact that Anna Dorai was not harmed, further weakened the prosecution’s case. The court emphasized that suspicion cannot replace proof, and the prosecution failed to establish the guilt of the accused beyond a reasonable doubt.

Fact:Law Ratio:

The court gave more weight to factual inconsistencies (60%) in the prosecution’s case, such as the medical evidence and the conduct of the witnesses, than to legal considerations (40%).

Logical Reasoning:

The court considered alternative interpretations but rejected them due to the strong contradictions in the evidence. The final decision was based on the conclusion that the prosecution failed to prove the guilt of the accused beyond a reasonable doubt. The court emphasized that the medical evidence, particularly the timing of the injuries, did not support the prosecution’s claim of custodial assault at the police station. The court also noted the unnatural conduct of the eyewitnesses and the improbability of the victim climbing stairs after sustaining such severe injuries.

“The injuries were fresh and must have occurred within six to eight hours of the death.”

“A man would be depressed and his expression and movements will be painful.”

“The prosecution has failed to bring home the guilt of both the accused persons.”

There were no majority or minority opinions in this case; the decision was unanimous.

Key Takeaways

• Importance of Reliable Evidence: This case underscores the necessity of reliable and consistent evidence in criminal cases, especially those involving custodial violence.
• Medical Evidence: Medical evidence can play a critical role in determining the truth of allegations of custodial torture, and can outweigh ocular testimony if it is more convincing.
• Witness Credibility: Courts must carefully assess the credibility of witnesses, considering their conduct and consistency.
• Burden of Proof: The prosecution must prove the guilt of the accused beyond a reasonable doubt, and suspicion cannot replace proof.
• Custodial Violence: The case highlights the need for thorough investigation in cases of custodial death, including the possibility of violence in prison.

Directions

The Supreme Court did not give any specific directions in this case other than to set aside the judgments of the trial court and the High Court and acquit the accused.

Development of Law

The ratio decidendi of this case is that when there are significant contradictions between eyewitness testimony and medical evidence, and the medical evidence strongly suggests that the injuries occurred at a different time or place than alleged, the courts must give greater weight to the medical evidence. This case reinforces the principle that suspicion cannot replace proof and that the prosecution must establish the guilt of the accused beyond a reasonable doubt. There is no change in the previous positions of law, but it emphasizes the importance of a thorough investigation and the need to consider all possible scenarios.

Conclusion

The Supreme Court acquitted the police officers, Vinod Jaswantray Vyas and Chinubhai Govindbhai Patel, in a custodial death case, citing inconsistencies in eyewitness testimony and contradictions with medical evidence. The court emphasized the importance of reliable evidence and the need to prove guilt beyond a reasonable doubt. The judgment highlights the critical role of medical evidence in cases of alleged custodial violence and the necessity of a thorough investigation.

Category:

• Indian Penal Code, 1860
  • Section 302, Indian Penal Code, 1860
  • Section 304, Indian Penal Code, 1860
• Criminal Law
  • Custodial Violence
  • Criminal Procedure
  • Evidence Law
• Supreme Court Judgments
  • Criminal Appeals
  • Acquittal

FAQ

Q: What was the main issue in the Vinod Jaswantray Vyas vs. State of Gujarat case?
A: The main issue was whether the police officers were guilty of causing the custodial death of an accused, given the inconsistencies in the evidence.

Q: What did the Supreme Court decide in this case?
A: The Supreme Court acquitted the police officers, finding that the prosecution failed to prove their guilt beyond a reasonable doubt.

Q: Why did the Supreme Court acquit the accused?
A: The Supreme Court found that the eyewitness testimony was inconsistent and unreliable, and the medical evidence contradicted the prosecution’s claims of custodial assault.

Q: What is the significance of medical evidence in cases of custodial violence?
A: Medical evidence plays a critical role in determining the truth of allegations of custodial torture and can outweigh eyewitness testimony if it is more convincing.

Q: What does this judgment mean for future cases of custodial death?
A: This judgment emphasizes the need for thorough investigations, reliable evidence, and a careful assessment of witness credibility in cases of custodial death.

Q: What is the difference between Section 302 and Section 304 Part I of the Indian Penal Code, 1860?
A: Section 302 deals with murder, while Section 304 Part I deals with culpable homicide not amounting to murder. The key difference lies in the intention and the circumstances surrounding the death.