Supreme Court overturns acquittal in quadruple murder case: State of Madhya Pradesh vs. Chhaakki Lal (2018)

Case Background

On February 20, 2006, at approximately 12:00-12:30 PM, Kesar Bai (PW-1), her daughter-in-law Phoolwati, and her three-year-old grandson Rinku were walking towards their field to harvest mustard crops. Ganeshi Bai, Kesar Bai’s daughter, and Ganga Singh, the son of Ganeshi Bai’s jeth, were slightly ahead of them. Near Madhawala Danda, Kesar Bai heard gunshots and saw the accused, Chhaakki Lal and his son Akhilesh, firing at Ganga Singh and Ganeshi Bai. The accused then approached Kesar Bai, stating they had killed Ganeshi Bai and Ganga Singh and that it was now her turn. Chhaakki Lal shot Phoolwati in the abdomen, and Akhilesh shot at Rinku. Chhaakki Lal then jumped on Rinku, causing the child’s intestines to come out, resulting in his immediate death. Kesar Bai challenged the accused, but Chhaakki Lal said he would not kill her, as she would die after witnessing the events.

A complaint (Dehati Nalishi, Ex. P-1) was recorded on the same day, and an FIR was registered against Chhaakki Lal and Akhilesh under Section 302 of the Indian Penal Code, 1860, read with Section 34, and Sections 25, 27, 29, and 30 of the Arms Act.

Timeline

The following table presents a chronological timeline of the events as mentioned in the judgment:

Course of Proceedings

The trial court convicted Chhaakki Lal and Akhilesh under Section 302 of the Indian Penal Code, 1860, read with Section 34, and sentenced them to death, finding the case to be in the ‘rarest of rare’ category. The High Court of Madhya Pradesh, however, overturned the trial court’s decision, acquitting the accused. The High Court found the evidence of the sole eyewitness, Kesar Bai (PW-1), to be unreliable due to inconsistencies and omissions in her testimony. The State of Madhya Pradesh then appealed to the Supreme Court against this acquittal.

Legal Framework

The following legal provisions were central to the case:

• Section 302 of the Indian Penal Code, 1860: This section defines the punishment for murder. The court had to determine if the accused were guilty of murder under this provision.
  “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
• Section 34 of the Indian Penal Code, 1860: This section deals with acts done by several persons in furtherance of common intention. It was invoked as the accused were alleged to have committed the crime together.
  “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.”
• Sections 25, 27, 29 and 30 of the Arms Act: These sections relate to the possession and use of illegal weapons.
• Section 27 of the Indian Evidence Act, 1872: This section deals with the admissibility of information leading to the discovery of a fact. It was used to admit the recovery of weapons based on the accused’s statements.
  “Provided that, when any fact is deposed to as discovered in consequence of information received from a person accused of any offence, in the custody of a police officer, so much of such information, whether it amounts to a confession or not, as relates distinctly to the fact thereby discovered, may be proved.”
• Section 134 of the Indian Evidence Act, 1872: This section states that no particular number of witnesses is required for the proof of any fact.
  “No particular number of witnesses shall in any case be required for the proof of any fact.”

Arguments

The State of Madhya Pradesh argued that Kesar Bai’s testimony was credible and supported by other evidence. They contended that the delay in sending the weapons to the Forensic Science Laboratory (FSL) was a minor oversight and should not benefit the accused. The State further argued that the High Court was wrong to believe the defense’s claim that dacoits were responsible for the murders.

The accused argued that Kesar Bai’s testimony was unreliable due to significant contradictions and improvements in her court depositions compared to her initial police complaint. They pointed out that Kesar Bai’s court deposition included witnessing the murders of Ganga Singh and Ganeshi Bai, which was not mentioned in her initial complaint. They also highlighted the improved version of Kesar Bai’s testimony regarding Chhaakki Lal throwing Rinku on the ground and jumping on his abdomen, which was not in the FIR. The defense also raised concerns about the mention of another assailant, Kailash, by Kesar Bai during cross-examination.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the High Court was right in reversing the verdict of conviction of the respondents-accused and acquitting them from the charges under Section 302 of the Indian Penal Code, 1860.

Treatment of the Issue by the Court

The following table demonstrates how the Court addressed the issue:

Authorities

The Court considered the following authorities:

Judgment

The Supreme Court overturned the High Court’s acquittal and restored the trial court’s conviction of Chhaakki Lal under Section 302 of the Indian Penal Code, 1860. The Court found that the High Court had erred in doubting the testimony of Kesar Bai (PW-1), the sole eyewitness, and that her evidence was credible and corroborated by medical and ballistic evidence. The Court held that minor inconsistencies in Kesar Bai’s testimony did not undermine its overall reliability.

The Court also considered the following:

The court also examined how the authorities were used:

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the credibility of the sole eyewitness, Kesar Bai (PW-1), and the corroborating evidence. The court found that the High Court had placed undue emphasis on minor inconsistencies in her testimony, overlooking the overall reliability of her account. The court also considered the corroborating medical and ballistic evidence, which supported the prosecution’s case. The court emphasized that the trial court had the opportunity to observe the demeanor of the witnesses and found their evidence to be credible. The court also noted that the High Court did not appreciate the evidence of PW-1 in the proper perspective.

The sentiment analysis of the reasons given by the Supreme Court is as follows:

The ratio of fact to law that influenced the court is as follows:

The Court’s logical reasoning for the main issue is as follows:

The court rejected alternative interpretations by stating that:

• The High Court placed undue emphasis on minor inconsistencies in Kesar Bai’s testimony.
• The High Court failed to consider the corroborating evidence.
• The High Court did not appreciate the evidence of PW-1 in the proper perspective.
• The High Court acted on surmises and findings of the impugned judgment is unreasonable.

The court’s final decision was reached by:

• Reappraising the evidence and reasoning of the trial court and the High Court.
• Finding that the High Court’s judgment suffered from serious infirmity.
• Restoring the trial court’s conviction of the accused under Section 302 of the Indian Penal Code, 1860.

The reasons for the decision were:

• The High Court erred in doubting the testimony of Kesar Bai (PW-1).
• Kesar Bai’s evidence was corroborated by medical and ballistic evidence.
• Minor contradictions in Kesar Bai’s testimony were not material.
• The High Court did not appreciate the evidence of PW-1 in the proper perspective.

The court quoted the following from the judgment:

• “In our considered view, the High court erred in doubting the testimony of Kesar Bai (PW-1).”
• “The High Court did not appreciate the evidence of PW-1 in proper perspective and erred in disbelieving her version on the contradictions which are not material.”
• “Where the evidence has not been properly analysed or the High court has acted on surmises and findings of the impugned judgment is unreasonable, it is the duty of the appellate court to set right the wrong.”

Key Takeaways

• The Supreme Court emphasized that the testimony of a single eyewitness can be reliable if it is credible and trustworthy.
• Minor inconsistencies in a witness’s statement should not automatically undermine their credibility, especially if the overall evidence has a ring of truth.
• Omissions or lapses in investigation by the investigating officer should not be a ground to discard the prosecution case if the case is otherwise credible and cogent.
• The appellate courts should not interfere with the findings of the trial court unless the appreciation of evidence by the trial court was vitiated by serious error.

Directions

The Supreme Court directed that the respondent/accused Chhaakki Lal shall surrender himself forthwith within a week to serve the remaining sentence, failing which he shall be taken into custody.

Development of Law

The ratio decidendi of the case is that the testimony of a single eyewitness can be reliable if it is credible and trustworthy, and minor inconsistencies in a witness’s statement should not automatically undermine their credibility. This judgment reinforces the principle that the quality of evidence is more important than the quantity and that the appellate courts should not interfere with the findings of the trial court unless the appreciation of evidence by the trial court was vitiated by serious error. There is no change in the previous positions of law.

Conclusion

The Supreme Court’s decision in State of Madhya Pradesh vs. Chhaakki Lal overturns the High Court’s acquittal, reinstating the trial court’s conviction of the accused for the murder of four individuals. The judgment underscores the importance of the quality of evidence over quantity and highlights that minor inconsistencies in a witness’s testimony should not automatically lead to its rejection. This case serves as a reminder that the testimony of a single eyewitness can be reliable if it is credible and trustworthy.