Supreme Court overturns conviction in murder case due to lack of credible evidence: Sudhakar vs. State (2018)

Date of the Judgment: 12 March 2018

Citation: 2018 INSC 206

Judges: N.V. Ramana, J. and S. Abdul Nazeer, J.

Can a conviction for murder stand when the prosecution’s case relies heavily on the testimony of closely related witnesses with a potential motive to falsely implicate the accused? The Supreme Court of India addressed this critical question in the case of *Sudhakar @ Sudharasan vs. State Rep. by the Inspector of Police*. The Court ultimately overturned the conviction, highlighting significant inconsistencies and a lack of independent corroboration in the prosecution’s evidence. The judgment was delivered by a bench comprising Justices N.V. Ramana and S. Abdul Nazeer, with Justice Ramana authoring the opinion.

Case Background

The prosecution’s case was that the appellant, Sudhakar, a habitual drunkard, frequently quarreled with his grandmother, Mariyayee, demanding money. On January 17, 2013, at approximately 6:30 p.m., Sudhakar was allegedly seen strangling his grandmother in her house by Jayaraj (PW1), the deceased’s son-in-law. Jayaraj, who was in an adjacent room, rushed to the scene upon hearing Mariyayee’s screams. According to the prosecution, Sudhakar then took a money bag from Mariyayee and fled.

Jayaraj took Mariyayee to the hospital, informing his wife, Maruthayee (PW5), about the incident. Mariyayee was admitted to the hospital at 7:30 p.m. but passed away at 7:55 p.m. Jayaraj filed a complaint at the Srirangam Police Station at 11:30 p.m., leading to the registration of a case against Sudhakar. The police recovered a money bag from Sudhakar after his arrest.

The post-mortem examination revealed that Mariyayee had abrasions, contusions, fractures of the thyroid cartilage and tracheal rings, bruising of the chest wall, and fractures of the left collar bone and manubrium sterni. The doctor concluded that the death was due to compression of the neck and chest.

Timeline:

Course of Proceedings

The trial court convicted Sudhakar under Section 302 of the Indian Penal Code, 1860, sentencing him to life imprisonment and a fine. The court relied on the testimonies of PW1 and PW5, concluding that Sudhakar had a motive to commit the crime due to his demands for money. The court also noted that the medical evidence supported the cause of death as compression of the neck and chest.

Sudhakar appealed to the High Court of Judicature at Madras, which upheld the trial court’s decision, stating that the conviction was in accordance with the law and did not suffer from any infirmity. The High Court dismissed the appeal.

Legal Framework

The primary legal provision in this case is Section 302 of the Indian Penal Code, 1860, which 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.”

Arguments

Appellant’s Arguments:

• The appellant’s counsel argued that the prosecution’s case was full of inconsistencies and that the courts below erred in disbelieving the appellant’s alibi that he was at his mother-in-law’s house at the time of the incident.
• The prosecution failed to establish a motive for the crime. The witnesses, PW1 and PW5, were interested witnesses who had a grudge against the appellant due to property disputes and wanted to implicate him to prevent him from inheriting family property.
• There were no independent witnesses to the crime, and there was a delay in lodging the complaint and in the FIR reaching the Judicial Magistrate.
• PW5 initially stated at the hospital that her mother had fallen down, which was recorded in the Accident Register as ‘history of fall’. However, she later changed her statement in court.
• The post-mortem report indicated fractures that were more consistent with a fall than with strangulation.

State’s Arguments:

• The State argued that the trial court and High Court rightly relied on the consistent evidence of PW1, who was an eyewitness, and that the medical evidence corroborated the prosecution’s case.
• The accused was a habitual drunkard who often quarreled with his grandmother for money.
• The recovery of the money bag from the accused substantiated the commission of the crime.
• The defense of alibi was not supported by any evidence, and the defense did not question the Investigating Officer about the arrest of the accused from his mother-in-law’s house.

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. Whether both the Courts below were right in convicting the accused for the offence punishable under Section 302, IPC.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

How each authority was viewed by the Court?

• Sarwan Singh v. State of Punjab, (1976 (4) SCC 369): The Court used this case to highlight the need for careful scrutiny of the evidence of interested witnesses.
• State of U.P. v. Kishanpal and Ors. , (2008) 16 SCC 73: The Court relied on this case to distinguish between related and interested witnesses, noting that PW1 and PW5 were both related and interested.
• Latesh V. State of Maharastra [Criminal Appeal No. 1301 of 2015, decided on January 30, 2018]: The Court used this case to explain the concept of reasonable doubt, emphasizing that it should be a practical one and not an illusory hypothesis.

What weighed in the mind of the Court?

The Supreme Court’s decision was heavily influenced by the lack of credible evidence and the presence of significant inconsistencies in the prosecution’s case. The Court emphasized the following points:

• The prosecution’s case relied heavily on the testimonies of PW1 and PW5, who were not only related to the accused but also had a clear motive to falsely implicate him due to property disputes.
• The absence of independent witnesses and the contradictory statements made by PW5 regarding the cause of the victim’s injuries raised serious doubts about the prosecution’s version of events.
• The Court highlighted the discrepancies in the testimonies of the prosecution witnesses, particularly regarding the arrest of the accused and the lodging of the complaint.
• The Court also noted the lack of a clear motive and the failure of the prosecution to provide a satisfactory explanation for several key aspects of the case.

The Court considered alternative interpretations of the evidence, particularly the possibility that the deceased’s injuries were caused by a fall rather than strangulation. However, the Court ultimately rejected the prosecution’s case due to the numerous inconsistencies and the lack of credible evidence. The Court concluded that the prosecution had failed to prove the guilt of the accused beyond a reasonable doubt.

The Court stated, “The prosecution has, therefore, failed to establish the guilt of the accused-appellant beyond reasonable doubt by adducing cogent evidence.”

The Court further noted, “We are satisfied that the Courts below completely misdirected themselves and the conviction imposed upon the accused by the trial Court and confirmed by the High Court suffers from patent error of law and perversity of approach and deserves to be set aside.”

The Court also highlighted, “In view of the above discussion, we are of the view that there exists reasonable doubt in this case as the case of prosecution is un-supported by independent witnesses, ridden with contradictions, good motive for false prosecution and filled with suspicious circumstances.”

Key Takeaways

• The judgment emphasizes the importance of independent witnesses in criminal cases, particularly when the prosecution relies on the testimonies of closely related or interested witnesses.
• It highlights the need for courts to carefully scrutinize the evidence presented by the prosecution, especially when there are inconsistencies or contradictions in the testimonies of witnesses.
• The judgment underscores the principle that the prosecution must prove the guilt of the accused beyond a reasonable doubt, and that a conviction cannot be sustained if there is a lack of credible evidence.
• The judgment serves as a reminder that the courts must be cautious while evaluating the evidence of related and interested witnesses to avoid the possibility of false implication.

Directions

The Supreme Court directed that the appellant, who was in jail, be set free immediately unless required in any other case.

Specific Amendments Analysis

There were no specific amendments discussed in this judgment.

Development of Law

The ratio decidendi of this case is that a conviction for murder cannot be sustained when the prosecution’s case is primarily based on the testimonies of interested witnesses, lacks independent corroboration, and is riddled with inconsistencies and contradictions. This judgment reinforces the principle that the burden of proof lies with the prosecution to establish the guilt of the accused beyond a reasonable doubt.

Conclusion

In *Sudhakar @ Sudharasan vs. State Rep. by the Inspector of Police*, the Supreme Court overturned the conviction of the appellant for the murder of his grandmother, citing a lack of credible evidence and significant inconsistencies in the prosecution’s case. The Court emphasized the importance of independent witnesses, the need for careful scrutiny of interested witnesses’ testimonies, and the principle of reasonable doubt. This judgment reinforces the high standard of proof required in criminal cases and serves as a reminder of the judiciary’s role in safeguarding individual liberties.