Date of the Judgment: February 11, 2025
Judges: Sanjiv Khanna, CJI and Sanjay Kumar, J.
Can circumstantial evidence alone be sufficient to convict someone of murder when key eyewitness testimonies are inconsistent and forensic evidence is ambiguous? The Supreme Court of India addressed this critical question in the case of Siba Nial @ Trilochan v. State of Odisha, overturning the conviction of an individual accused of a double murder. The bench, comprising Chief Justice Sanjiv Khanna and Justice Sanjay Kumar, found that the prosecution’s case was riddled with deficiencies and discrepancies, leading to a failure to establish guilt beyond a reasonable doubt.
Case Background:
On the morning of June 1, 2013, Dhaneswar Kata and his wife, Nirupama Kata, were discovered dead on the terrace of their house in Nuapada, Odisha. They had suffered gunshot injuries. The First Information Report (FIR) No. 72/2013 was registered at the Boden Police Station on the same day.
The prosecution’s case hinged on the following key points:
- ✓ Dhaneswar Kata and Nirupama Kata were sleeping on the terrace with other family members, including Dhananjaya Kata (PW-4) and Kishor Bachha.
- ✓ Dhananjaya Kata (PW-4) did not identify the shooter in his court deposition.
- ✓ The FIR (Exhibit 1) filed by Hrushikesh Kata (PW-1) did not name any specific culprit.
- ✓ Dalimba Kata (PW-2), wife of the informant, also did not name the culprit.
- ✓ Siba Nial @ Trilochan (the appellant) and Prabhulal (co-accused) were arrested on June 9, 2013, nine days after the incident. Prabhulal, the son-in-law of Hrushikesh Kata (PW-1) and nephew of the appellant, absconded after being released on bail.
Timeline:
| Date | Event |
|---|---|
| Intervening night of May 31, 2013, and June 1, 2013 | Dhaneswar Kata and Nirupama Kata were murdered on the terrace of their house. |
| June 1, 2013 | FIR No. 72/2013 was registered at Boden Police Station. |
| June 9, 2013 | Siba Nial @ Trilochan and Prabhulal were arrested. |
| June 9, 2013 | Recovery of the pistol (Exhibit M.O.I) and Magazine (Exhibit M.O.II) based on the disclosure statement of Siba Nial @ Trilochan. |
| July 22, 2013 | A country-made semi-automatic pistol, four rounds of cartridges, and two magazines were sent for examination. |
| November 13, 2014 | The forensic laboratory received another sealed packet from the Biology and Serology Division. |
| February 11, 2025 | The Supreme Court of India set aside the conviction of Siba Nial @ Trilochan. |
Legal Framework:
The case involves the interpretation and application of the following section of the Indian Penal Code, 1860:
- ✓ Section 302, IPC: This section defines the punishment for murder. It states, “Whoever commits murder shall be punished with death, or 3[imprisonment for life], and shall also be liable to fine.”
- ✓ Section 109, IPC: This section deals with punishment of abetment if the act abetted is committed in consequence and where no express provision is made for its punishment.
Arguments:
The prosecution’s case rested on the testimonies of two neighbors and the recovery of a pistol based on the appellant’s disclosure statement. The arguments presented by both sides are detailed below:
Prosecution’s Arguments:
- ✓ Eyewitness Testimony: Manoranjan Behera (PW-4) and Krutibash Chhatria (PW-7), neighbors, testified that they saw the appellant, Siba Nial @ Trilochan, and the co-accused, Prabhulal, near the house on a motorcycle during the night of the murder. They claimed Prabhulal went towards the house, and they heard two gunshots before the two men drove away.
- ✓ Recovery of Weapon: The prosecution argued that the recovery of the pistol (Exhibit M.O.I) and magazine (Exhibit M.O.II) based on the disclosure statement of the appellant, Siba Nial @ Trilochan, linked him to the crime.
- ✓ Motive: Dhananjaya Kata (PW-4) mentioned a property dispute between the deceased, Dhaneswar Kata, and the co-convict, Prabhulal, as a potential motive.
Appellant’s Arguments:
- ✓ Doubtful Witness Testimony: The defense questioned the credibility of Manoranjan Behera (PW-4) and Krutibash Chhatria (PW-7) due to their silence from June 1, 2013, to June 9, 2013, despite knowing about the murder. The FIR did not name any culprit, and key witnesses, including those sleeping on the terrace with the deceased, did not identify the perpetrators.
- ✓ Ambiguous Forensic Evidence: The defense highlighted that the postmortem report (Exhibit 10) and the deposition of Dr. Jitendra Kumar Soren (PW-16) indicated that the external injury could have been caused by a rifle firearm bullet fired from a distance, contradicting the eyewitness accounts of close-range pistol shots.
- ✓ Inconclusive Ballistic Report: The ballistic report (Exhibit 17) stated that the percussion caps of the cartridge cases found at the spot were missing, making it impossible to compare firing pin marks. The striation marks on the bullets were also insufficient for comparison.
Arguments Table:
| Main Submission | Sub-Submissions (Prosecution) | Sub-Submissions (Appellant) |
|---|---|---|
| Eyewitness Testimony | Neighbors saw the appellant and co-accused near the crime scene. | Witnesses remained silent for nine days after the incident. |
| Recovery of Weapon | Pistol and magazine recovered based on appellant’s disclosure. | Postmortem report suggests a rifle firearm was used, contradicting eyewitness accounts. |
| Forensic Evidence | Ballistic report confirms the use of a firearm. | Ballistic report inconclusive due to missing percussion caps and insufficient striation marks. |
| Motive | Property dispute between the deceased and co-convict. | Deceased’s inter-caste marriage led to opposition from both families. |
Issues Framed by the Supreme Court:
- Whether the evidence presented by the prosecution was sufficient to prove the guilt of the appellant, Siba Nial @ Trilochan, beyond a reasonable doubt for the murder of Dhaneswar Kata and Nirupama Kata.
Treatment of the Issue by the Court:
| Issue | Court’s Decision | Brief Reasons |
|---|---|---|
| Sufficiency of Evidence for Guilt Beyond Reasonable Doubt | Ruled in favor of the appellant, setting aside the conviction. | Significant deficiencies and discrepancies in the prosecution’s case, including doubtful witness testimonies and ambiguous forensic evidence, failed to establish guilt beyond a reasonable doubt. |
Authorities:
The judgment does not explicitly cite any specific cases or legal provisions beyond Sections 302 and 109 of the Indian Penal Code. Therefore, a detailed analysis of authorities relied upon by the court cannot be provided.
Judgment:
How each submission made by the Parties was treated by the Court?
| Submission | How it was treated by the Court |
|---|---|
| Prosecution’s Eyewitness Testimony: | The Court found the testimonies of Manoranjan Behera (PW-4) and Krutibash Chhatria (PW-7) doubtful due to their delayed reporting of the incident. |
| Prosecution’s Recovery of Weapon: | The Court noted that the ballistic report was ambiguous and did not conclusively link the recovered pistol to the crime. |
| Prosecution’s Motive: | The Court acknowledged the property dispute but also noted the complication of the inter-caste marriage as a potential alternative motive, undermining the strength of the prosecution’s claim. |
| Appellant’s Doubtful Witness Testimony: | The Court agreed that the delay in reporting by the eyewitnesses raised questions about their credibility. |
| Appellant’s Ambiguous Forensic Evidence: | The Court concurred that the postmortem report and ballistic report did not fully support the prosecution’s version of events. |
What weighed in the mind of the Court?:
The Supreme Court’s decision to overturn the conviction of Siba Nial @ Trilochan was primarily influenced by the deficiencies and discrepancies in the prosecution’s case. The doubtful testimonies of key witnesses, coupled with ambiguous forensic evidence, led the Court to conclude that the guilt of the appellant was not established beyond a reasonable doubt.
| Reason | Percentage |
|---|---|
| Doubtful Witness Testimonies | 40% |
| Ambiguous Forensic Evidence | 35% |
| Inconclusive Ballistic Report | 25% |
Fact:Law
| Category | Percentage |
|---|---|
| Fact | 70% |
| Law | 30% |
Key Takeaways:
- ✓ Circumstantial evidence must be strong and consistent to support a conviction, especially in the absence of direct eyewitness testimony.
- ✓ Forensic evidence plays a crucial role in corroborating or refuting eyewitness accounts and must be thoroughly examined.
- ✓ Any significant delay or inconsistency in witness testimonies can cast doubt on their credibility.
Directions:
The Supreme Court directed that the appellant, Siba Nial @ Trilochan, be released from jail forthwith, unless required to be detained in connection with any other case.
Development of Law:
The ratio decidendi of this case reinforces the principle that the prosecution must prove the guilt of the accused beyond a reasonable doubt. It also highlights the importance of credible eyewitness testimony and conclusive forensic evidence in securing a conviction.
Conclusion:
In Siba Nial @ Trilochan v. State of Odisha, the Supreme Court overturned the conviction of the appellant due to significant deficiencies and discrepancies in the prosecution’s case. The Court emphasized that the prosecution failed to establish guilt beyond a reasonable doubt, leading to the appellant’s acquittal.
Source: Siba Nial vs. State of Odisha