Supreme Court Upholds Conviction Based on Admitted Documents in Murder Case: Shyam Narayan Ram vs. State of U.P. (21 October 2024)

Date of the Judgment: 21 October 2024
Citation: 2024 INSC 800
Judges: Vikram Nath, J. and Prasanna B. Varale, J.

Can a criminal trial be overturned simply because the defense counsel admitted the genuineness of prosecution documents, thereby avoiding the need for formal proof? The Supreme Court of India recently addressed this critical question in a case involving a brutal double murder. This judgment clarifies the scope and application of Section 294 of the Code of Criminal Procedure, 1973, which deals with the admissibility of documents in court. The bench, comprising Justices Vikram Nath and Prasanna B. Varale, delivered a unanimous verdict, setting aside the Allahabad High Court’s order for a retrial.

Case Background

The case revolves around a horrific incident that occurred on the intervening night of April 21 and 22, 1998. Shyam Narayan Ram (PW1), the appellant, and Ram Dular (PW2) were harvesting crops when they heard gunshots. Rushing towards the source of the noise, they witnessed four accused individuals assaulting the appellant’s parents, Bodha Devi and Mohan Ram, who belonged to the Scheduled Caste. After the brutal assault, the accused threw the bodies of the victims into a well.

Following the incident, the appellant lodged a First Information Report (FIR) on April 22, 1998, at 5:30 am, which was registered as FIR No. 27/1998 at Police Station Dhanapur, District Chandauli, U.P. The case was registered under Section 302/34 of the Indian Penal Code, 1860 and Section 3(1)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The police recovered the bodies from the well. Post-mortem examinations revealed that Bodha Devi had suffered seven injuries, including a fatal wound to her back, while Mohan Ram had sustained sixteen injuries. The cause of death for both was attributed to injuries to the spine and spinal cord.

During the investigation, a blood-soaked scarf belonging to one of the accused, Pratap (A-2), was recovered, along with a licensed SBBL gun and live cartridges. Forensic analysis confirmed that one of the recovered cartridges had been fired from the seized gun, and residues in the gun barrel indicated recent use.

Timeline:

Course of Proceedings

Following the submission of the charge sheet, the Magistrate took cognizance and committed the case to the Sessions Court for trial. The charges were read out to the four accused, who denied them and claimed to be tried. The prosecution presented the informant (PW1) and another eye-witness (PW2), along with relevant documents.

On April 28, 2005, the defense counsel admitted the genuineness of the prosecution documents, dispensing with the need for formal proof. The Public Prosecutor’s application to summon formal witnesses was opposed by the defense. The Trial Court then exhibited the prosecution papers and closed the prosecution evidence, fixing a date for recording statements of the accused under Section 313 of the Code of Criminal Procedure, 1973 (CrPC).

Despite recording statements under Section 313 CrPC in 2005, the trial was stayed by the High Court and resumed in 2019. The Public Prosecutor again requested the court to summon the doctor who conducted the autopsies and the Investigating Officer, which was again opposed by the defense.

The Trial Court convicted all four accused on July 15/16, 2019. The accused then appealed to the Allahabad High Court, which, on November 1, 2023, set aside the conviction, citing a lack of fair trial due to the defense counsel’s admission of documents. The High Court ordered a retrial from the stage of PW2’s testimony, allowing the defense to cross-examine PW2 and the prosecution to produce formal witnesses.

Legal Framework

The Supreme Court focused on Section 294 of the Code of Criminal Procedure, 1973 (CrPC), which deals with the admissibility of documents without formal proof.

Section 294 of the CrPC states:

“Section 294 – No formal proof of certain documents
(1) Where any document is filed before any Court by the prosecution or the accused, the particulars of every such document shall be included in a list and the prosecution or the accused, as the case may be, or the pleader for the prosecution or the accused, if any, shall be called upon to admit or deny the genuineness of each such document.
(2) The list of documents shall be in such form as may be prescribed by the State Government.
(3) Where the genuineness of any document is not disputed, such document may be read in evidence in any inquiry, trial or other proceeding under this Code without proof of the signature of the person to whom it purports to be signed:
Provided that the Court may, in its discretion, require such signature to be proved.”

This section allows documents to be admitted as evidence without requiring the testimony of the person who signed them, provided the genuineness of the document is not disputed. The court, however, retains the discretion to require proof of the signature if deemed necessary.

Arguments

Appellant’s Arguments:

• The appellant argued that the High Court erred in remanding the matter for retrial.
• The appellant contended that the defense counsel had repeatedly admitted the genuineness of the prosecution documents, and therefore, Section 294 of the CrPC was applicable.
• The appellant submitted that the High Court’s decision would render Section 294 CrPC redundant.
• The appellant argued that the defense’s admission of documents was not due to any error or oversight but was a conscious decision, as they had opposed the recall of witnesses by the Public Prosecutor on multiple occasions.
• The appellant asserted that the High Court should have decided the appeal on merits based on the available evidence.

Respondent (State of U.P.) Arguments:

• The State of U.P. supported the appellant’s case, stating that the Public Prosecutor’s requests to produce formal witnesses were rejected due to the defense’s opposition.
• The State argued that there was no justification for remitting the matter back to the Trial Court for a retrial.

Respondent (Accused) Arguments:

• The accused supported the High Court’s judgment, emphasizing the need for a fair trial.
• The accused did not deny the defense counsel’s actions in admitting the documents but argued that the principles of fair trial should be considered.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section. However, the core issue before the court was:

• Whether the High Court was justified in setting aside the Trial Court’s conviction and ordering a retrial based on the argument that the accused did not receive a fair trial due to their counsel admitting the genuineness of prosecution documents.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The Supreme Court considered the following authorities:

Judgment

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

How each authority was viewed by the Court?

• The Supreme Court followed the principles laid down in Sonu alias Amar vs. State of Haryana [2017] 8 SCC 570*, which clarified the procedure for filing documents in court under Section 294 of the CrPC.
• The Supreme Court also followed Shamsher Singh Verma vs. State of Haryana [2016] 15 SCC 485*, stating that the admission or denial of documents under Section 294 CrPC can be made by the counsel for the defense.
• The Supreme Court relied on Akhtar vs. State of Uttaranchal [2009] 13 SCC 722*, which held that if the genuineness of a document is not disputed, it can be read as substantive evidence under Section 294(3) CrPC.
• The Supreme Court distinguished the case of Munna Pandey vs. State of Bihar [2023] SCC OnLine SC 1103*, which the High Court had relied upon, stating that it dealt with fair trial issues concerning the confrontation of witnesses and not with the application of Section 294 CrPC.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the consistent application of Section 294 of the CrPC and the repeated admission of the genuineness of prosecution documents by the defense counsel. The Court emphasized that the defense’s actions were not due to any oversight but a deliberate strategy. The Court found that the High Court’s decision to order a retrial was not justified and would render the provisions of Section 294 CrPC redundant.

Fact:Law Ratio

The Supreme Court’s reasoning was heavily based on the interpretation and application of Section 294 of the CrPC, which is a legal consideration. The factual aspects of the case, such as the defense counsel’s actions and the circumstances of the trial, were also considered.

The Supreme Court reasoned that the High Court’s decision was flawed as it overlooked the significance of Section 294 of the CrPC, which allows for the admission of documents without formal proof if their genuineness is not disputed. The defense counsel’s repeated admission of the documents’ genuineness was a crucial factor in the court’s decision. The Court emphasized that the Trial Court had correctly relied on these admitted documents, and therefore, the High Court’s order for a retrial was not justified.

The Court rejected the argument that the accused did not receive a fair trial. The Court noted that the defense counsel’s admission of documents was a deliberate strategy and not an oversight. The Court also stated that the High Court should have decided the appeal on the merits of the evidence on record, instead of ordering a retrial.

The Court quoted the following from the judgment in support of its reasoning:

• “where the genuineness of any document is not disputed, such document may be read in evidence in any inquiry, trial or other proceeding under this Code without proof of the signature of the person to whom it purports to be signed.”
• “The Trial Court had rightly relied upon the same and exhibited them in view of the specific repeated stand taken by the defence in admitting the genuineness of the said documents.”
• “It is settled position of law that if the genuineness of any document filed by a party is not disputed by the opposite party it can be read as substantive evidence under sub-section (3) of Section 294 CrPC.”

Key Takeaways

• Section 294 CrPC Application: The judgment clarifies that if the genuineness of a document is admitted by the defense, it can be read as evidence without formal proof.
• Defense Counsel’s Role: The actions of the defense counsel in admitting documents are binding on the accused, and such admissions cannot be easily reversed.
• Fair Trial: Admitting documents under Section 294 CrPC does not violate the principles of a fair trial.
• High Court’s Error: The High Court erred in ordering a retrial based on the defense counsel’s admission of documents.
• Importance of Evidence: The Supreme Court emphasized the importance of deciding cases based on the evidence available on record.

Directions

The Supreme Court directed the following:

• The High Court’s judgment was set aside, and the criminal appeals were restored for fresh hearing on merits.
• The High Court was requested to expedite the hearing and decision of the appeals based on the evidence led during the trial.
• The private respondents (accused) were directed to surrender before the Trial Court within six weeks, with the option to apply for suspension of sentence before the High Court.

Development of Law

The ratio decidendi of this case is that when the defense counsel admits the genuineness of prosecution documents, those documents can be admitted as evidence without formal proof under Section 294 of the CrPC. This judgment reinforces the settled position of law regarding the application of Section 294 of the CrPC and emphasizes that such admission does not violate the principles of a fair trial. There is no change in the previous position of law, but the judgment clarifies the application of the provision in specific circumstances where the defense counsel admits the documents.

Conclusion

In conclusion, the Supreme Court’s judgment in Shyam Narayan Ram vs. State of U.P. & Anr. clarifies the application of Section 294 of the Code of Criminal Procedure, 1973, and reinforces the principle that if the defense admits the genuineness of prosecution documents, those documents can be admitted as evidence without formal proof. The Court set aside the Allahabad High Court’s order for a retrial, emphasizing that the defense’s actions were a conscious decision and not an oversight. This judgment upholds the importance of deciding cases based on the evidence available on record and ensures that the provisions of Section 294 CrPC are not rendered redundant.