Supreme Court Upholds Conviction in Daylight Murder Case Despite Lack of Motive: Chandan vs. State (2024) INSC 271

Introduction

Date of the Judgment: April 05, 2024

Citation: 2024 INSC 271

Judges: Justice Sudhanshu Dhulia and Justice Prasanna B. Varale

Can a murder conviction stand when there is a credible eyewitness, even if the prosecution cannot prove why the accused committed the crime? The Supreme Court of India recently addressed this question in a case involving a daylight murder. The Court examined whether the lack of a motive weakens the prosecution’s case when there is direct evidence from a reliable eyewitness.

In this case, the appellant was convicted under Section 302 of the Indian Penal Code, 1860 for murder. The conviction was based primarily on the testimony of an eyewitness who saw the appellant stabbing the deceased. The High Court upheld the conviction, and the matter reached the Supreme Court. The key question before the Supreme Court was whether the absence of a proven motive undermines the reliability of the eyewitness account. The judgment was delivered by a bench of Justice Sudhanshu Dhulia and Justice Prasanna B. Varale.

Case Background

On May 28, 1993, at approximately 8:15 PM, PW-2, the sister-in-law of the deceased, was returning from Ram Bazar. She noticed the deceased, Rakesh, and the accused, Chandan, walking ahead of her. Shortly after, she witnessed them grappling, and then saw Chandan stabbing Rakesh multiple times with a knife. Rakesh fell to the ground, and Chandan fled the scene.

Rakesh was taken to a nearby private clinic and then to Hindu Rao Hospital, where he was declared dead. The post-mortem examination, conducted on May 29, 1993, revealed several incised stab wounds. The medical examiner concluded that the cause of death was shock and hemorrhage due to the injuries, particularly one that penetrated the chest cavity and damaged the heart.

An FIR was registered on the same day at the Kashmere Gate Police Station based on PW-2’s statement. The police investigation led to a charge sheet against Chandan under Section 302 of the Indian Penal Code, 1860. During the trial, the prosecution presented 18 witnesses, with PW-2 being the key eyewitness.

The accused was apprehended shortly after the incident with a blood-stained knife and shirt. Forensic evidence confirmed that the blood on the knife matched the deceased’s blood.

Timeline

Legal Framework

The case primarily revolves around Section 302 of the Indian Penal Code, 1860, which deals with the punishment for murder.

Section 302 of the Indian Penal Code, 1860 states:

“Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”

The prosecution’s case was built on the eyewitness testimony and the recovery of the murder weapon, which was linked to the crime through forensic evidence. The defense argued that the prosecution failed to establish a motive for the murder, which they claimed weakened the case.

Arguments

The prosecution’s main argument was based on the direct eyewitness testimony of PW-2, who saw the accused stabbing the deceased. They also presented forensic evidence linking the recovered knife to the crime. The prosecution contended that the eyewitness account was reliable and consistent, and the recovery of the murder weapon further corroborated their case.

The defense argued that the prosecution failed to establish any motive for the murder. They questioned the manner in which the knife was recovered, suggesting that there were doubts about the process. The defense emphasized that the absence of a motive should cast doubt on the prosecution’s case.

The prosecution relied on several Supreme Court cases to argue that the absence of motive is not significant when there is direct eyewitness testimony. They cited cases like Shivaji Genu Mohite v. State of Maharashtra, AIR 1973 SC 55, where it was held that the prosecution is not required to establish motive when there is a reliable eyewitness. They also cited Bikau Pandey v. State of Bihar, (2003) 12 SCC 616; Rajagopal v. Muthupandi, (2017) 11 SCC 120; and Yogesh Singh v. Mahabeer Singh, (2017) 11 SCC 195, which reiterated the same principle.

The defense did not cite any specific case laws but focused on discrediting the prosecution’s evidence by highlighting the lack of motive and raising questions about the recovery of the knife.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section, but the core issue that the court addressed was:

• Whether the lack of a proven motive weakens the prosecution’s case when there is direct evidence from a reliable eyewitness.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

The Supreme Court upheld the conviction of the appellant under Section 302 of the Indian Penal Code, 1860. The Court found that the prosecution had successfully proven its case beyond a reasonable doubt, primarily based on the reliable eyewitness testimony and corroborating forensic evidence.

The Court emphasized that the lack of motive is not a significant factor when there is direct evidence from a reliable eyewitness. The Court also noted that the murder, the arrest of the accused, and the recovery of the weapon happened in quick succession, which further supported the prosecution’s case.

The following authorities were viewed by the Court as follows:

✓ Shivaji Genu Mohite v. State of Maharashtra, AIR 1973 SC 55*: The Court relied on this case to reiterate that when ocular testimony inspires confidence, the prosecution is not required to establish motive.

✓ Bikau Pandey v. State of Bihar, (2003) 12 SCC 616*: The Court followed this precedent, stating that the lack or absence of motive is inconsequential when direct evidence establishes the crime.

✓ Rajagopal v. Muthupandi, (2017) 11 SCC 120*: This case was cited to reinforce the principle that motive is not significant when direct evidence is present.

✓ Yogesh Singh v. Mahabeer Singh, (2017) 11 SCC 195*: The Court used this case to further support its position that the absence of motive does not render eyewitness testimony untrustworthy.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the reliability of the eyewitness testimony and the corroborating forensic evidence. The Court emphasized that the presence of a credible eyewitness diminishes the importance of establishing a motive. The quick succession of events—the murder, the arrest, and the recovery of the weapon—also played a crucial role in solidifying the prosecution’s case.

The following table shows the ratio of fact to law that influenced the court:

The Court’s reasoning can be summarized as follows:

The Court considered the argument that the prosecution had not established a motive, but it rejected this argument, stating:

“The argument of the defence that the prosecution has not been able to establish any motive on the accused for committing this dastardly act is in fact true, but since this is a case of eye-witness where there is nothing to discredit the eye-witness, the motive itself is of little relevance.”

The Court further explained its reasoning by stating:

“In case the prosecution is not able to discover an impelling motive, that could not reflect upon the credibility of a witness proved to be a reliable eye-witness. Evidence as to motive would, no doubt, go a long way in cases wholly dependent on circumstantial evidence. Such evidence would form one of the links in the chain of circumstantial evidence in such a case. But that would not be so in cases where there are eye-witnesses of credibility…”

The Court concluded that:

“The entire evidence put together by the prosecution does establish the guilt of the accused beyond a reasonable doubt.”

Key Takeaways

The Supreme Court’s judgment has the following practical implications:

• ✓ In cases of direct eyewitness testimony, the prosecution is not required to establish a motive for the crime.
• ✓ The testimony of a reliable eyewitness is sufficient to secure a conviction, even if the prosecution cannot prove why the accused committed the crime.
• ✓ The absence of motive is only significant in cases based on circumstantial evidence.
• ✓ Forensic evidence that corroborates eyewitness testimony strengthens the prosecution’s case.

Directions

The Supreme Court directed that the interim bail granted to the appellant was vacated, and the appellant was ordered to surrender before the Trial Court within four weeks. The Court also directed that a copy of the judgment be sent to the Trial Court to ensure the appellant undergoes the remaining part of his sentence.

Specific Amendments Analysis

There were no specific amendments discussed in the judgment.

Development of Law

The ratio decidendi of this case is that in cases where there is direct and reliable eyewitness testimony, the prosecution is not required to prove the motive behind the crime for a conviction under Section 302 of the Indian Penal Code, 1860. This judgment reinforces the existing legal position that the absence of motive is inconsequential when there is direct evidence of guilt. There is no change in the previous position of law.

Conclusion

In conclusion, the Supreme Court dismissed the appeal and upheld the conviction of the appellant under Section 302 of the Indian Penal Code, 1860. The Court reiterated that the presence of a reliable eyewitness is sufficient to establish guilt, even if the prosecution cannot prove the motive behind the crime. This judgment reinforces the importance of direct evidence in criminal cases and clarifies that the absence of motive does not weaken the prosecution’s case when there is credible eyewitness testimony.