Supreme Court overturns acquittal in murder case, upholds conviction of main accused: State of Punjab vs. Gurpreet Singh (2024) INSC 154 (06 February 2024)

Date of the Judgment: 06 February 2024

Citation: 2024 INSC 154

Judges: Surya Kant, J., K.V. Viswanathan, J.

Can a High Court’s acquittal be overturned by the Supreme Court if the High Court misreads evidence? The Supreme Court of India recently addressed this question in a case where the High Court had acquitted the accused in a murder case, disagreeing with the Trial Court’s conviction. This case revolves around the murder of Amarjit Kaur, where the primary accused was her daughter’s former husband, Gurpreet Singh.

The Supreme Court, in this judgment, examined the circumstances under which it can interfere with a High Court’s acquittal order, especially when the High Court’s decision appears to be based on a misreading of evidence. The bench comprised Justices Surya Kant and K.V. Viswanathan, with the judgment authored by Justice Surya Kant.

Case Background

On 18th July 2012, a First Information Report (FIR) was registered at Police Station City Jagraon, District Ludhiana Rural, concerning the murder of Amarjit Kaur. The complainant, Gursewak Singh (P.W.2), reported that his daughter, Kirandeep Kaur, was previously married to Gurpreet Singh (the main accused) but they divorced in 2011.

On the day of the incident, around 1:30 PM, Gursewak Singh was resting when his wife, Amarjit Kaur, informed him that someone was at the door. Upon opening the door, Gursewak Singh saw Gurpreet Singh, accompanied by another person, who had jumped over the compound wall. Gurpreet Singh, armed with a pistol, shot Amarjit Kaur at close range. Gursewak Singh also saw Gurpreet Singh’s brothers, Harpreet Singh and Joga Singh, near an Innova car outside the gate.

The motive, according to the complainant, was that Gurpreet Singh blamed Amarjit Kaur for his divorce from Kirandeep Kaur, which prevented him from settling in Australia.

Timeline

Course of Proceedings

The Trial Court found Gurpreet Singh guilty of murder under Section 302 of the Indian Penal Code, 1860 (IPC), and his co-accused guilty under Section 302 read with Section 34 of the IPC. They were all sentenced to life imprisonment.

The High Court, however, acquitted all the accused, disbelieving the testimonies of Gursewak Singh (P.W.2) and his daughter, Harmandeep Kaur (P.W.3). The High Court raised doubts about the timing of Gursewak Singh’s return from a hospital, his failure to initially name all the accused, and Harmandeep Kaur’s presence at her parental home after marriage.

Legal Framework

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

• Section 302 of the IPC: This section defines 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 34 of the IPC: This section deals with acts done by several persons in furtherance of common intention. It states, “When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.”

Arguments

Arguments by the State of Punjab:

• The High Court erred in acquitting the accused by setting aside the well-reasoned findings of the Trial Court.
• The direct and unequivocal statements of the witnesses (P.W.2 and P.W.3) proved that Gurpreet Singh shot Amarjit Kaur.
• The witnesses had no motive to falsely implicate the accused.
• Gurpreet Singh had a motive to kill Amarjit Kaur due to his divorce and shattered dreams of settling in Australia.
• P.W.3 identified the accused at the police station and in court.

Arguments by the Respondents:

• The Supreme Court should be cautious in interfering with a High Court’s acquittal order.
• It is strange that none of the neighbors witnessed the crime, which occurred in broad daylight.
• The testimonies of P.W.2 and P.W.3 are not reliable.
• P.W.3 was unlikely to be attending classes from her paternal home after her marriage.

Issues Framed by the Supreme Court

The Supreme Court framed the following issues for consideration:

1. Whether a case is made out for interference by this Court under Article 136 of the Constitution.
2. Whether the acquittal of Respondents is sustainable, if the answer to the first question is in the affirmative.

Treatment of the Issue by the Court

Authorities

The following authorities were considered by the Supreme Court:

Judgment

How each authority was viewed by the Court?

• State of Karnataka v. J. Jayalalitha [2017] 6 SCC 263*: The court acknowledged the principle that a judgment of acquittal strengthens the presumption of innocence but also highlighted the court’s responsibility to prevent miscarriage of justice.
• Rajesh Prasad v. State of Bihar [2022] 3 SCC 471*: The court used this case to outline the principles guiding its intervention in acquittal orders under Article 136, particularly when the High Court’s approach is perverse or leads to a miscarriage of justice.
• Thoti Manohar v. State Of Andhra Pradesh [2012] SCC 7 723*: The court referred to this case to support the view that family members are natural witnesses in cases occurring within the confines of a house.
• Nand Lal v. State of Chhattisgarh [2023] 10 SCC 470*: The court cited this case to emphasize that prompt lodging of an FIR helps dispel suspicions and adds credibility to the prosecution’s argument.
• Thulia Kali v. State Of Tamil Nadu [1972] 3 SCC 393*: The court used this case to reiterate that a promptly lodged FIR reflects the first-hand account of the incident.
• State of Punjab v. Surja Ram 1995 Supp (3) SCC 419*: The court used this case to reiterate that a promptly lodged FIR reflects the first-hand account of the incident.
• Girish Yadav v. State of M.P [1996] 8 SCC 186*: The court used this case to reiterate that a promptly lodged FIR reflects the first-hand account of the incident.
• Takdir Samsuddin Sheikh v. State of Gujarat [2011] 10 SCC 158*: The court used this case to reiterate that a promptly lodged FIR reflects the first-hand account of the incident.

What weighed in the mind of the Court?

The Supreme Court’s decision to overturn the High Court’s acquittal of Gurpreet Singh was primarily influenced by the following factors:

• The direct and consistent testimonies of the eyewitnesses (P.W.2 and P.W.3), which were deemed natural and trustworthy.
• The prompt reporting of the crime by Gursewak Singh (P.W.2) to the Police Control Room.
• The recovery of the weapon of crime (pistol) from Gurpreet Singh, based on his disclosure statement.
• The established motive of Gurpreet Singh to kill Amarjit Kaur due to his divorce and failed plans to settle in Australia.
• The High Court’s misreading of evidence and assigning perverse reasons for disbelieving the witnesses.

Fact:Law Ratio

The Supreme Court’s decision was influenced more by the factual aspects of the case, such as the eyewitness testimonies, the prompt reporting of the crime, the recovery of the weapon, and the established motive, than by purely legal considerations. The court emphasized the misreading of facts by the High Court, which led to a miscarriage of justice.

Logical Reasoning

Key Takeaways

• The Supreme Court can interfere with a High Court’s acquittal order if the High Court’s decision is based on a misreading of evidence or perverse reasoning.
• Prompt reporting of a crime and the testimonies of natural witnesses are crucial in establishing the prosecution’s case.
• Recovery of the weapon of crime based on the accused’s disclosure statement is strong evidence.
• A motive, when established, can strengthen the prosecution’s case.
• The High Court’s reasoning for acquitting Gurpreet Singh was found to be illogical and untenable.

Directions

The Supreme Court directed the following:

• The acquittal of Gurpreet Singh was set aside, and his conviction by the Trial Court was restored.
• Gurpreet Singh’s bail bonds were cancelled, and he was directed to surrender and be taken into custody to serve the remainder of his sentence.
• The appeals against the acquittal of Kashmira Singh, Jagdeep Singh, and Harpreet Singh were dismissed.

Specific Amendments Analysis

There are no specific amendments discussed in this judgment.

Development of Law

The ratio decidendi of this case is that the Supreme Court can and will interfere with a High Court’s acquittal order when the High Court’s decision is based on a misreading of evidence or perverse reasoning. This judgment reinforces the importance of direct and consistent testimonies of natural witnesses, prompt reporting of crimes, and the significance of recovering the weapon of crime. It also emphasizes that a well-established motive can strengthen the prosecution’s case. This case does not change any previous positions of law but reinforces the existing principles of criminal jurisprudence.

Conclusion

In conclusion, the Supreme Court partly allowed the appeal, setting aside the High Court’s acquittal of Gurpreet Singh and restoring the Trial Court’s conviction. The court found that the High Court had misread the evidence and assigned perverse reasons for disbelieving the eyewitnesses. However, the court upheld the acquittal of the co-accused due to a lack of sufficient evidence to implicate them in the crime. This judgment underscores the Supreme Court’s role in correcting miscarriages of justice and ensuring that convictions based on sound evidence are upheld.

Category

Parent Category: Indian Penal Code, 1860

Child Categories:

• Section 302, Indian Penal Code, 1860
• Section 34, Indian Penal Code, 1860
• Criminal Law
• Murder
• Acquittal
• Conviction
• Eyewitness Testimony
• Motive
• Evidence
• Supreme Court Judgments

Parent Category: Criminal Procedure

Child Categories:

• First Information Report
• Article 136, Constitution of India

FAQ

Q: Can a High Court’s acquittal be overturned by the Supreme Court?

A: Yes, the Supreme Court can overturn a High Court’s acquittal if it finds that the High Court misread the evidence or used perverse reasoning.

Q: What is the significance of eyewitness testimony in a murder case?

A: Eyewitness testimony, especially from natural witnesses, is crucial in establishing the prosecution’s case, provided the witnesses are deemed trustworthy and their testimonies are consistent.

Q: How does the recovery of a weapon affect a murder case?

A: The recovery of the weapon of crime, especially when based on the accused’s disclosure statement, is strong evidence that can significantly strengthen the prosecution’s case.

Q: What role does motive play in a murder case?

A: While motive is not always necessary to prove guilt, a well-established motive can strengthen the prosecution’s case by providing a reason for the accused to commit the crime.

Q: What should one do if they are an eyewitness to a crime?

A: If you are an eyewitness to a crime, it is important to report it to the police as soon as possible. Your testimony can be crucial in bringing the perpetrators to justice.