Supreme Court Upholds Conviction in Murder Case: Motiram Padu Joshi vs. State of Maharashtra (2018)

Date of the Judgment: 10 July 2018
Citation: [Not Available in Source]
Judges: Ranjan Gogoi, J. and R. Banumathi, J.
Can a High Court reverse a trial court’s acquittal in a murder case? The Supreme Court of India addressed this question in a recent judgment, examining the evidence and circumstances of a brutal attack. This case involves a dispute between political factions that escalated into a fatal assault, raising questions about the credibility of witnesses and the role of the appellate court. The Supreme Court upheld the conviction, finding that the High Court was correct in reversing the trial court’s acquittal. The judgment was authored by Justice R. Banumathi.

Case Background

The case revolves around the murder of Machindra Budhaji Joshi on April 26, 1992, in village Owa-peth, Taluka Panvel, District Raigad. Machindra, along with his brother Anant (PW-2) and colleagues Kesarinath (PW-3) and Vasudeo (PW-4), were involved in electric fitting work. The appellants, Motiram Padu Joshi (A3), Ratan Maruti Vaskar (A5), Devidas Maruti Vaskar (A7), and Ramnath @ Ram Padu Joshi (A8), were associated with the Congress party, while the deceased and prosecution witnesses belonged to the Shiv Sena party. This political rivalry led to animosity between the two groups, culminating in the violent attack.

On the night of the incident, Machindra, along with PWs 3 and 4, returned from work in Nandgaon at around 8:30 PM. After dinner, they were sitting in the courtyard of Machindra’s house. Around 9:30 PM, the appellants, along with other accused, arrived armed with swords, knives, sticks, and a motorcycle chain. The appellants attacked Machindra, causing grievous injuries. PWs 3 and 4, witnessing the attack, retreated inside the house out of fear. Machindra was taken to the hospital but succumbed to his injuries later that night.

Timeline

Course of Proceedings

The trial court acquitted all the accused, citing doubts about the credibility of PW-2 and the presence of PWs 3 and 4. The trial court also noted that the prosecution had not proven the guilt of the accused beyond a reasonable doubt. The High Court of Judicature at Bombay, however, reversed the trial court’s decision, finding the evidence of PWs 2 to 4 consistent and corroborated by medical evidence and the recovery of weapons. The High Court convicted the appellants under Sections 147, 148, 302 read with 149 of the Indian Penal Code (IPC), sentencing them to life imprisonment.

Legal Framework

The case primarily involves the following sections of the Indian Penal Code (IPC):

• Section 147, IPC: “Punishment for rioting.” This section deals with the offense of rioting.
• Section 148, IPC: “Rioting, armed with deadly weapon.” This section addresses rioting while being armed with a deadly weapon.
• Section 302, IPC: “Punishment for murder.” This section defines the punishment for committing murder.
• Section 149, IPC: “Every member of unlawful assembly guilty of offence committed in prosecution of common object.” This section states that if an offense is committed by any member of an unlawful assembly in furtherance of the common object of that assembly, every person who was a member of the same assembly at the time of the commission of that offense is guilty of that offense.

Arguments

The appellants argued that:

• PW-2, despite being present, did not attempt to rescue his brother and remained a mute spectator.
• PW-2 has a criminal record, making his testimony unreliable.
• The names of PWs 3 and 4 were not mentioned in the First Information Report (FIR), raising doubts about their credibility.
• PWs 3 and 4 did not intervene to save the deceased, making their presence at the scene doubtful.
• The presence of mud on the deceased’s body casts doubt on the place and time of the incident.
• The High Court should not have interfered with the trial court’s acquittal without compelling reasons.

The State of Maharashtra argued that:

• The evidence of PWs 2 to 4 was consistent and corroborated by medical evidence and recovery of weapons.
• The trial court erred in disbelieving the eye witnesses’ testimonies.
• The FIR was promptly registered, lending credence to the prosecution’s case.
• The High Court was correct in reversing the trial court’s acquittal due to perversity in the trial court’s findings.

The innovativeness of the argument by the appellants was to attack the credibility of the witnesses based on their conduct during the incident and their past records, while the State focused on the consistency and corroboration of the evidence.

Issues Framed by the Supreme Court

The Supreme Court considered the following issues:

1. Whether the High Court was justified in reversing the judgment of acquittal passed by the trial court.
2. Whether the evidence of eye witnesses (PWs 2 to 4) was credible and reliable.
3. Whether the High Court was correct in convicting the appellants based on the available evidence.

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

The Supreme Court upheld the High Court’s decision, confirming the conviction of the appellants under Section 302 of the Indian Penal Code (IPC) read with Section 149 of the IPC and the sentence of life imprisonment.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the consistent testimonies of the eye witnesses (PWs 2 to 4), the corroborating medical evidence, and the recovery of weapons. The Court emphasized that the trial court had erred in disregarding these pieces of evidence and gave undue importance to minor inconsistencies and the conduct of witnesses. The prompt registration of the FIR also lent credibility to the prosecution’s case. The Court found that the High Court had correctly assessed the evidence and reversed the trial court’s perverse findings.

The Court rejected the appellants’ arguments, stating that the High Court had rightly reversed the trial court’s decision. The Court noted that the trial court had focused on insignificant aspects and failed to appreciate the core of the prosecution’s case. The Supreme Court found no reason to interfere with the High Court’s judgment.

The Court also quoted the following from the judgment:

• “Evidence of a witness is not to be disbelieved simply because he has not reacted in a particular manner.”
• “FIR is not an encyclopedia which is expected to contain all the details of the prosecution case.”
• “Every person who witnesses a murder reacts in his own way. There is no set rule of natural reaction.”

Key Takeaways

• The Supreme Court upheld the High Court’s decision to reverse the trial court’s acquittal in a murder case.
• The evidence of eye witnesses, if consistent and corroborated by medical evidence and other material evidence, is considered reliable.
• The conduct of witnesses at the scene of a crime is not a rigid factor for assessing their credibility.
• Appellate courts have the power to re-appreciate evidence and reverse acquittals if the trial court’s findings are perverse.
• Prompt registration of the FIR lends credibility to the prosecution’s case.

Directions

The Supreme Court did not provide any specific directions in this case, other than upholding the conviction and sentence of the appellants.

Development of Law

The ratio decidendi of this case is that the appellate court can reverse the order of acquittal passed by the trial court if the findings of the trial court are perverse and the evidence of the eye witnesses is consistent and corroborated by medical and other evidence. This case reaffirms the principles regarding the powers of appellate courts in appeals against acquittal and the credibility of witnesses. There is no change in the previous position of law, but the judgment clarifies how the existing principles should be applied in specific cases.

Conclusion

In conclusion, the Supreme Court’s judgment in Motiram Padu Joshi vs. State of Maharashtra reinforces the principle that appellate courts can and should intervene when trial court decisions are based on flawed reasoning and a misappreciation of evidence. The case highlights the importance of consistent witness testimony, corroborating evidence, and the proper application of legal principles in criminal trials. The Supreme Court upheld the conviction of the appellants, ensuring that justice was served in a case marked by political rivalry and violence.