Supreme Court overturns conviction in murder case due to flawed evidence: Munikrishna vs. State (2022)

Date of the Judgment: 30 September 2022

Citation: 2022 INSC 476

Judges: Uday Umesh Lalit, CJI, S. Ravindra Bhat, J, Sudhanshu Dhulia, J (authored the judgment)

Can a conviction be upheld based on a confession made to the police, which is inadmissible under the law? The Supreme Court of India recently addressed this critical question in a criminal appeal, overturning a lower court’s decision. This case highlights the importance of adhering to established legal principles in criminal trials, particularly concerning the admissibility of evidence and the evaluation of circumstantial evidence. The Supreme Court bench, comprising Chief Justice Uday Umesh Lalit, Justice S. Ravindra Bhat, and Justice Sudhanshu Dhulia, delivered the judgment, authored by Justice Dhulia.

Case Background

On the night of October 11, 2000, S. Ramakrishnan, a 72-year-old man living alone in Bengaluru, was murdered in his home. His son-in-law, S. Ramakrishnan, filed a First Information Report (FIR) on October 12, 2000, after discovering his father-in-law’s body. The deceased had last spoken to his daughter at 6:30 PM on October 11, 2000. The son-in-law and his wife, upon receiving a call from a neighbor about the house being open and lights on, rushed to the house and found the dead body in the kitchen. The police were informed, and an investigation began.

The Inquest report noted that the deceased was found in a pool of blood in the kitchen with a severe cut injury on his neck. A post-mortem examination revealed seven ante-mortem injuries, with the primary cause of death being a deep incised wound on the neck, which severed major blood vessels. The police investigation led to the arrest of five individuals, including the present appellants, in connection with another case. These individuals allegedly confessed to the murder of S. Ramakrishnan and led the police to the crime scene and to a jewelry shop where they had sold stolen gold.

Timeline:

Course of Proceedings

The Trial Court convicted the accused under Section 302 read with Section 34 of the Indian Penal Code (IPC), sentencing them to life imprisonment. The High Court of Karnataka upheld this conviction and sentence. The appellants then appealed to the Supreme Court of India, challenging the High Court’s decision.

Legal Framework

The case primarily revolves around the interpretation and application of the following legal provisions:

• Section 302 of the Indian Penal Code (IPC): This section defines the punishment for murder. “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 (IPC): This section deals with acts done by several persons in furtherance of common intention. “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.”
• Section 25 of the Indian Evidence Act, 1872: This section renders confessions made to a police officer inadmissible as evidence. “No confession made to a police officer, shall be proved as against a person accused of any offence.”
• Article 20(3) of the Constitution of India: This article protects an accused from being compelled to be a witness against himself. “No person accused of any offence shall be compelled to be a witness against himself.”

Arguments

Appellants’ Arguments:

• The appellants argued that the entire case was based on their confessional statements made while in police custody, which are inadmissible under Section 25 of the Indian Evidence Act, 1872.
• They contended that the so-called discovery of the weapon of crime and the stolen gold was flawed and doubtful.
• They argued that there was no direct or scientific evidence linking them to the crime.
• They submitted that the prosecution’s case was entirely based on circumstantial evidence, which did not form a complete chain pointing only to their guilt.
• They highlighted that the independent witness to the recovery of the weapon had turned hostile.
• They pointed out that the recovered gold was not identified by the deceased’s family as belonging to him.

Respondent’s Arguments:

• The respondent argued that the voluntary statements made by the accused, including the video recorded statements, were admissible as corroborative evidence.
• They contended that the accused had led the police to the crime scene, the weapon, and the stolen gold, which was sufficient evidence to prove their guilt.
• They argued that the circumstances pointed towards the guilt of the accused beyond reasonable doubt.
• They relied on the Trial Court and High Court’s findings, which had upheld the conviction based on the available evidence.

Issues Framed by the Supreme Court

The Supreme Court considered the following key issues:

1. Whether the confessional statements made by the accused to the police are admissible as evidence.
2. Whether the evidence presented by the prosecution was sufficient to prove the guilt of the accused beyond a reasonable doubt, especially given that the case was based on circumstantial evidence.
3. Whether the recovery of the weapon of crime and the stolen gold was valid and reliable.

Treatment of the Issue by the Court

The following table demonstrates how the Court decided the issues:

Authorities

The Supreme Court relied on the following authorities to reach its decision:

Judgment

The Supreme Court allowed the appeals, setting aside the orders of the Sessions Judge and the High Court. The Court held that the conviction was based on inadmissible evidence and flawed circumstantial evidence.

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

How each authority was viewed by the Court?

✓ The Supreme Court relied on Hanumant Govind Nargundkar & Anr. v. State of Madhya Pradesh [AIR 1952 SC 343]* and subsequent cases to emphasize the stringent requirements for proving guilt based on circumstantial evidence. The court held that the circumstances must be fully established and consistent only with the guilt of the accused.

✓ The Court held that the reliance of the Trial Court on Shri N. Sri Rama Reddy, Etc. v. Shri V.V. Giri [AIR 1971 SC 1162]* was misplaced as that case was not dealing with a criminal case and most certainly not on the admissibility of a statement given by an accused to the Police under Section 161 of Code of Criminal Procedure.

✓ The Court relied on Criminal Appeal Nos. 1476-1477 of 2018* to highlight the similar pattern of flawed investigation and reliance on inadmissible evidence in cases involving some of the same accused.

✓ The Court relied on Section 25 of the Indian Evidence Act, 1872 and Article 20(3) of the Constitution of India to hold that the confessional statements made to the police are inadmissible and that an accused cannot be compelled to be a witness against himself.

What weighed in the mind of the Court?

The Supreme Court was primarily concerned with the following:

• Adherence to Legal Principles: The Court emphasized the importance of adhering to established legal principles, particularly regarding the admissibility of evidence. The Court noted that the Trial Court and the High Court had ignored these principles by relying on confessional statements made to the police, which are inadmissible under Section 25 of the Indian Evidence Act, 1872.
• Flawed Investigation: The Court was critical of the police investigation, noting the lack of direct evidence, the doubtful recovery of the weapon and stolen gold, and the reliance on inadmissible confessional statements. This was compounded by the fact that the independent witness to the recovery of the weapon had turned hostile.
• Circumstantial Evidence: The Court reiterated that in cases of circumstantial evidence, the chain of evidence must be complete, and the circumstances must point only to the guilt of the accused, excluding every other reasonable hypothesis. The Court found that the prosecution failed to meet this standard.
• Protection of Rights of the Accused: The Court was mindful of the constitutional rights of the accused, particularly the right against self-incrimination under Article 20(3) of the Constitution of India. The Court held that the accused cannot be compelled to be a witness against himself and that confessions made to the police cannot be used as evidence against them.

Logical Reasoning:

The Court’s reasoning was that the prosecution’s case was built on inadmissible evidence and flawed circumstantial evidence. The Court emphasized that the prosecution failed to establish a complete chain of evidence pointing only to the guilt of the accused. The Court also noted that the Trial Court and the High Court had erred in relying on confessional statements made to the police and on a video recording of the accused’s statements, which are inadmissible under the Indian Evidence Act, 1872. The Court also highlighted the flawed nature of the recovery of the weapon and the stolen gold, further weakening the prosecution’s case.

The Court considered alternative interpretations of the evidence but rejected them, finding that the prosecution’s case did not meet the required standards for a conviction in a criminal trial. The Court held that the evidence did not exclude every reasonable hypothesis except the guilt of the accused, as required in cases of circumstantial evidence. In particular, the Court rejected the argument that the video recorded statements of the accused could be used as corroborative evidence, clarifying that such statements are akin to confessions made to police and are thus inadmissible.

The Court concluded that the prosecution had failed to prove the guilt of the accused beyond a reasonable doubt. The Court held that the conviction was based on inadmissible evidence and flawed circumstantial evidence and, therefore, could not be sustained.

The majority opinion was authored by Justice Sudhanshu Dhulia, with the other judges concurring. There were no dissenting opinions.

“In a case of circumstantial evidence, the Court has to scrutinize each and every circumstantial possibility, which is placed before it in the form of an evidence and the evidence must point towards only one conclusion, which is the guilt of the accused.”

“Under Article 20(3) of the Constitution of India, an accused cannot be compelled to be a witness against himself. Again, under Section 25 of the Indian Evidence Act, 1872; a confessional statement given by an accused before a Police officer is inadmissible as evidence.”

“The crime indeed was ghastly, to say the least. Yet, linking the crime to the present appellants is an exercise which was to be undertaken in the court of law under established principles of law. This has not been done.”

Key Takeaways

• Confessional statements made to the police are inadmissible as evidence in a criminal trial.
• In cases of circumstantial evidence, the prosecution must establish a complete chain of evidence that points only to the guilt of the accused, excluding every other reasonable hypothesis.
• The recovery of evidence, such as weapons or stolen goods, must be reliable and corroborated by independent evidence.
• Courts must adhere to established legal principles and constitutional safeguards in criminal trials.
• The prosecution has a heavy burden to prove its case beyond a reasonable doubt.

Directions

The Supreme Court directed that the appellants be released from jail immediately, unless they are wanted in some other crime.

Development of Law

The ratio decidendi of this case is that a conviction cannot be based on inadmissible evidence, such as confessional statements made to the police, and that circumstantial evidence must form a complete chain pointing only to the guilt of the accused. This judgment reinforces the importance of adhering to established legal principles and constitutional safeguards in criminal trials. It also highlights the need for a thorough and reliable investigation by law enforcement agencies. There is no change in the previous position of law but the Supreme Court has re-emphasized the importance of the existing legal principles.

Conclusion

The Supreme Court’s decision in Munikrishna @ Krishna Etc. vs. State by Ulsoor PS overturns the conviction of the appellants, emphasizing the inadmissibility of confessional statements made to the police and the need for a complete chain of circumstantial evidence. This judgment serves as a critical reminder of the importance of adhering to established legal principles in criminal trials and protecting the rights of the accused.