Supreme Court Upholds Acquittal in Murder Case Due to Discrepancy in Weapon and Injury: State of Madhya Pradesh vs. Amar Lal (2019)

Introduction

Date of the Judgment: December 10, 2019

Citation: Not Available

Judges: Ashok Bhushan, J., Navin Sinha, J.

Can an acquittal in a murder case be upheld if the medical evidence contradicts the alleged weapon used in the assault? The Supreme Court of India recently addressed this question in a case where the High Court acquitted the accused due to a mismatch between the weapon described by eyewitnesses and the nature of the injuries sustained by the deceased. This case highlights the importance of consistency between ocular and medical evidence in criminal trials. The judgment was delivered by a two-judge bench comprising Justices Ashok Bhushan and Navin Sinha, with Justice Navin Sinha authoring the opinion.

Case Background

The case revolves around an incident that occurred on March 27, 1990, where the respondent, Amar Lal, allegedly assaulted the deceased using the pointed end of a wooden plough. The prosecution’s case relied heavily on the testimonies of two eyewitnesses, PW-4 and PW-5, who were family members of the deceased. PW-5 was also an injured witness in the same incident. The prosecution argued that the respondent’s assault with the sharp, nail-studded end of the plough resulted in the victim’s death. However, the medical evidence presented by the doctor, PW-6, indicated that the injuries were likely caused by a blunt, hard object rather than a sharp, nail-embedded one. The High Court, based on this discrepancy, acquitted the respondent of the murder charge under Section 302 of the Indian Penal Code (IPC), while upholding his conviction under Section 323 of the IPC for causing simple hurt.

Timeline

Course of Proceedings

The Trial Court convicted the respondent on January 24, 1995. The respondent was in custody from that date till November 18, 2006. The High Court, however, overturned the conviction under Section 302 of the Indian Penal Code, citing the discrepancy between the weapon used and the nature of the injury. The State of Madhya Pradesh then appealed to the Supreme Court against this acquittal.

Legal Framework

The case primarily involves the interpretation and application of Section 302 of the Indian Penal Code (IPC), which deals with the punishment for murder. It also involves Section 323 of the Indian Penal Code (IPC), which addresses the punishment for voluntarily causing hurt. The core legal issue is whether the High Court was justified in acquitting the respondent of murder based on a perceived contradiction between the eyewitness testimony and the medical evidence.

Section 302 of the Indian Penal Code (IPC) states, “Punishment for murder.—Whoever commits murder shall be punished with death, or [imprisonment for life], and shall also be liable to fine.”

Section 323 of the Indian Penal Code (IPC) states, “Punishment for voluntarily causing hurt.—Whoever, except in the case provided by section 334, voluntarily causes hurt, shall be punished with imprisonment of either description for a term which may extend to one year, or with fine which may extend to one thousand rupees, or with both.”

Arguments

Appellant’s Arguments (State of Madhya Pradesh):

• The State argued that the High Court erred in acquitting the respondent despite the presence of credible eyewitness testimony from PW-4 and PW-5, who were family members of the deceased.
• The State contended that the High Court placed undue emphasis on the medical opinion of PW-6, the doctor, who stated that the injuries were caused by a blunt object, while ignoring the fact that the eyewitnesses saw the respondent assaulting the deceased with the pointed end of a wooden plough.
• The State submitted that the eyewitnesses were not doubted, and PW-5 was also an injured witness in the same incident, which further strengthens the prosecution’s case.

Respondent’s Arguments (Amar Lal):

• The respondent’s counsel, Mr. Anukul Chandra Pradhan, argued that the respondent had already served a substantial period of 14 years, 6 months, and 7 days in custody.
• The respondent did not directly address the discrepancy in the nature of injuries and the weapon used, but focused on the period of incarceration already served.

Issues Framed by the Supreme Court

• Whether the High Court was justified in acquitting the respondent under Section 302 of the Indian Penal Code, given the eyewitness testimony and the nature of the injuries sustained by the deceased.

Treatment of the Issue by the Court

Authorities

The judgment does not explicitly cite any case laws or legal provisions other than Section 302 of the Indian Penal Code (IPC) and Section 323 of the Indian Penal Code (IPC). The court’s decision was primarily based on the facts and circumstances of the case, particularly the discrepancy between the eyewitness testimony and the medical evidence, and the substantial period of incarceration already served by the respondent.

Judgment

The Supreme Court, after considering the submissions and the evidence, decided not to interfere with the High Court’s decision. The Court noted that the respondent had already served a significant period of 14 years, 6 months, and 7 days in custody. The Court did not explicitly address the discrepancy between the weapon and the injury but implicitly upheld the High Court’s decision, possibly due to the long period of incarceration.

There were no authorities cited by the Supreme Court in this judgment.

What weighed in the mind of the Court?

The primary factor that weighed in the mind of the Supreme Court was the substantial period of incarceration already served by the respondent. While the Court did not explicitly state that the High Court was correct in its reasoning regarding the discrepancy between the weapon and the injury, the Court’s decision not to interfere suggests that this discrepancy, combined with the long period of custody, influenced its decision. The court’s decision reflects a consideration of the practical implications of further prolonging the legal process, given the time the respondent had already spent in custody.

Key Takeaways

• Discrepancy between Evidence: The case highlights the importance of consistency between eyewitness testimony and medical evidence in criminal trials. A significant discrepancy can lead to an acquittal, even if there is eyewitness testimony.
• Period of Incarceration: The Supreme Court’s decision underscores that the period of incarceration served by an accused can be a significant factor in deciding whether to interfere with a lower court’s decision.
• Judicial Restraint: The Court’s decision also reflects a degree of judicial restraint, where it chose not to interfere with the High Court’s judgment, possibly due to the long period of incarceration and the factual discrepancies in the case.

Directions

No specific directions were given by the Supreme Court in this judgment.

Specific Amendments Analysis

There is no discussion on specific amendments in this judgment.

Development of Law

The ratio decidendi of this case is that a significant discrepancy between the weapon used in an assault as described by eyewitnesses and the nature of the injuries found by medical examination can lead to an acquittal. The court did not explicitly state that the High Court was correct in its reasoning regarding the discrepancy between the weapon and the injury, but the court’s decision not to interfere suggests that this discrepancy, combined with the long period of custody, influenced its decision. This case also reinforces the principle that the period of incarceration already served can be a significant factor in a court’s decision, especially in appeals against acquittals.

Conclusion

In the case of State of Madhya Pradesh vs. Amar Lal, the Supreme Court dismissed the appeal against the High Court’s acquittal of the respondent for murder under Section 302 of the Indian Penal Code. The acquittal was primarily based on the discrepancy between the alleged weapon used (a sharp-ended plough) and the nature of the injuries sustained by the deceased (blunt force trauma), as well as the fact that the respondent had already served a substantial period of 14 years, 6 months, and 7 days in custody. The Supreme Court’s decision underscores the importance of consistency between eyewitness and medical evidence in criminal trials, and it highlights the significance of the period of incarceration served by the accused.