Date of the Judgment: 25 February 2022
Citation: Suresh Yadav @ Guddu v. The State of Chhattisgarh, Criminal Appeal No. 1349 of 2013
Judges: Dinesh Maheshwari, J and Vikram Nath, J
Can the Supreme Court interfere with concurrent findings of fact by the Trial Court and High Court in a criminal appeal? The Supreme Court of India recently addressed this question in a case involving a murder conviction. The court upheld the conviction, emphasizing that it will not re-evaluate evidence unless there are significant errors of law or procedure. This judgment reinforces the principle that the Supreme Court will not act as a third court of fact. The bench comprised Justices Dinesh Maheshwari and Vikram Nath.
Case Background
The appellant, Suresh Yadav, was accused of murdering a woman with whom he had a relationship. The prosecution’s case was that the appellant, enraged by seeing the deceased talking to another boy, repeatedly stabbed her with a knife, causing her death. The incident led to the appellant’s conviction by the Trial Court under Section 302 of the Indian Penal Code (IPC) and Sections 25 and 27 of the Arms Act. The High Court upheld the conviction and sentence.
The prosecution presented evidence that the deceased suffered 12 injuries, including penetrating wounds to her lungs and liver, as detailed in the post-mortem report (Ex. P-21A). An eye-witness (PW-1) testified to seeing the appellant inflict the injuries. The prosecution also stated that the knife used in the crime was recovered based on the appellant’s disclosure.
Timeline
| Date | Event |
|---|---|
| 2004 | Sessions Case No. 05 of 2004 was initiated in the Court of Ninth Additional Sessions Judge (F.T.C.), Durg. |
| 07.09.2019 | Appellant was released under Section 432 of the Code of Criminal Procedure (CrPC) by the Government of Chhattisgarh after serving 15 years, 9 months, and 27 days of imprisonment. |
| 25 February 2022 | Supreme Court dismissed the appeal. |
Course of Proceedings
The Trial Court, after assessing the evidence, found the appellant guilty of murder and offenses under the Arms Act. The appellant was sentenced to life imprisonment for the murder. The High Court, on appeal, reviewed the evidence and affirmed the Trial Court’s decision, finding no reason to interfere with the conviction or the sentence.
Legal Framework
The case primarily concerns Section 302 of the Indian Penal Code, 1860, which defines the punishment for murder. It states:
“302. Punishment for murder.—Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
The case also involves Sections 25 and 27 of the Arms Act, related to the possession and use of illegal arms.
Section 432 of the Code of Criminal Procedure (CrPC) was also mentioned in the judgment, which deals with the power of the government to suspend or remit sentences.
Arguments
The learned amicus curiae (a lawyer appointed by the court to assist) raised the following arguments on behalf of the appellant:
- Lack of Blood Matching: There was no evidence to prove that the blood found on the knife matched the deceased’s blood.
- Unreliable Witness: The eye-witness (PW-1) was not reliable because he did not raise an alarm or try to save the deceased, despite the incident occurring in front of his house.
- Multiple Assailants: The excessive number of injuries on the deceased suggested that more than one person was involved in the crime.
The State, represented by its counsel, supported the findings of the Trial Court and the High Court, arguing that the evidence was sufficient to prove the appellant’s guilt.
| Main Submission | Sub-Submissions by Appellant | Sub-Submissions by State |
|---|---|---|
| Challenge to Evidence | ✓ Lack of blood matching on the knife. ✓ PW-1 was not a reliable witness. ✓ Excessive injuries suggest multiple assailants. |
✓ Supported the findings of the Trial Court and High Court. ✓ Evidence was sufficient to prove guilt. |
Issues Framed by the Supreme Court
The Supreme Court did not explicitly frame specific issues but considered whether there was any error in the concurrent findings of the Trial Court and the High Court that would warrant interference by the Supreme Court. The implicit issue was whether the Supreme Court should re-evaluate the evidence to reach a different conclusion.
Treatment of the Issue by the Court
| Issue | How the Court Dealt with It |
|---|---|
| Whether the Supreme Court should re-evaluate the evidence | The Court held that it would not interfere with concurrent findings of fact unless there was a misreading of evidence, an error of law or procedure, or a manifest illegality leading to a miscarriage of justice. The Court found no such errors in this case. |
Authorities
The Supreme Court relied on the following case to explain the scope of interference in appeals against concurrent findings of fact:
- Pappu v. State of Uttar Pradesh, Criminal Appeal Nos. 1097-1098 of 2018 (Supreme Court of India)
The Court cited the above case to clarify that it will not re-appreciate evidence unless there are errors of law or procedure, misreading of evidence, or disregard for judicial norms leading to serious prejudice or injustice.
| Authority | How it was considered by the Court |
|---|---|
| Pappu v. State of Uttar Pradesh, Criminal Appeal Nos. 1097-1098 of 2018 (Supreme Court of India) | Followed: The Court used this case to reiterate the principle that the Supreme Court will not interfere with concurrent findings of fact unless there are serious errors. |
Judgment
| Submission by Appellant | How it was treated by the Court |
|---|---|
| Lack of blood matching on the knife. | The Court did not find this to be a ground for interference. |
| PW-1 was not a reliable witness. | The Court upheld the credibility of PW-1, stating that his failure to raise an alarm or intervene did not make his testimony unreliable. |
| Excessive injuries suggest multiple assailants. | The Court stated that excessive injuries do not automatically imply multiple assailants but rather indicate repeated stabbing by the same person. |
The Court reiterated its position on the scope of appeals against concurrent findings, stating that it will not interfere unless there are significant errors of law or procedure. The Court found no such errors in this case.
| Authority | How it was viewed by the Court |
|---|---|
| Pappu v. State of Uttar Pradesh, Criminal Appeal Nos. 1097-1098 of 2018 (Supreme Court of India) | The Court followed this authority to emphasize that it is not a regular court of appeal for re-appreciation of evidence and will only interfere in rare cases of manifest illegality. |
What weighed in the mind of the Court?
The Court was primarily influenced by the concurrent findings of the Trial Court and the High Court, which had both found the evidence sufficient to convict the appellant. The Court emphasized that it would not re-evaluate evidence unless there were significant errors of law or procedure. The Court also gave importance to the testimony of the eye-witness (PW-1), which was deemed credible.
| Sentiment | Percentage |
|---|---|
| Concurrent Findings of Lower Courts | 40% |
| Credibility of Eye-Witness | 30% |
| Lack of Errors in Law or Procedure | 30% |
| Category | Percentage |
|---|---|
| Fact | 30% |
| Law | 70% |
The Court rejected the argument that the lack of blood matching on the knife was a sufficient reason to overturn the conviction. The Court also found the eye-witness’s testimony credible, even though he did not intervene during the incident. The Court noted that the number of injuries did not necessarily mean that there was more than one assailant.
The Court stated, “The submissions made before us are essentially for reappreciation of evidence or for taking a different view of the evidence than that has been taken by the Trial Court and the High Court.”
The Court also observed, “Even otherwise, we do not find the present one to be a case of manifest illegality so as to call for interference.”
The Court further stated, “Excessive number of injuries do not ipso facto lead to an inference about involvement of more than one person; rather the nature of injuries and similarity of their size/dimension would only lead to the inference that she was mercilessly and repeatedly stabbed by the same weapon and by the same person.”
Key Takeaways
- The Supreme Court will not interfere with concurrent findings of fact by the Trial Court and High Court unless there are significant errors of law or procedure.
- The credibility of an eye-witness is not automatically diminished if they do not intervene during a crime.
- Excessive injuries on a victim do not necessarily imply the involvement of multiple assailants.
Directions
The Supreme Court clarified that the dismissal of the appeal would not affect the remission granted to the appellant by the Government of Chhattisgarh under Section 432 of the Code of Criminal Procedure (CrPC).
Development of Law
The ratio decidendi of this case is that the Supreme Court will not interfere with concurrent findings of fact by the lower courts unless there are significant errors of law or procedure. This case reinforces the existing legal position on the scope of appeals against concurrent findings of fact.
Conclusion
The Supreme Court dismissed the appeal, upholding the conviction of the appellant for murder. The Court reiterated that it would not re-evaluate evidence unless there were significant errors of law or procedure. The judgment emphasizes the importance of concurrent findings by the lower courts and the limited scope of interference by the Supreme Court in such cases.