Supreme Court Upholds Conviction in Murder Case: Thatireddigari Maheswara Reddy vs. State of Andhra Pradesh (2024)

Date of the Judgment: July 8, 2024
Citation: 2024 INSC 495
Judges: Abhay S. Oka, J. and Pankaj Mithal, J.
Can the testimony of eyewitnesses who are related to the victim be considered reliable in a murder case? The Supreme Court of India recently addressed this question while upholding the conviction of an accused in a murder case. The court examined the reliability of eyewitness accounts, especially when the witnesses are family members of the deceased. The judgment was delivered by a two-judge bench comprising Justice Abhay S. Oka and Justice Pankaj Mithal.

Case Background

The case revolves around the murder of Shiva Prasad Reddy, a lawyer, who was attacked and killed on July 26, 1997. The prosecution’s case is that the deceased was a practicing lawyer at Gooty and resided in Peddavadugur village with his brothers. The deceased used to travel daily from his residence to the court at Gooty by motorcycle. The appellant, Thatireddigari Maheswara Reddy, was accused no. 2 in the case. The deceased had contested the election for the post of President of the Water Users Association of Peddavadugur village against the appellant and lost.

A few months after the election, the Excise Police raided the house of the appellant and seized illicit brandy, leading to a case against him. The appellant suspected that the deceased was responsible for the raid. Additionally, about twenty days before the incident, the Congress party had convened a meeting in the village, and the deceased was elected as the convenor of the Congress party. The Excise Police also booked a case against accused no. 1, who believed that the deceased was responsible for the action taken by the Excise Police. On the day of the incident, the deceased left his village between 9:00 am and 9:30 am to go to the Court at Gooty.

Later that day, the deceased’s brothers, PW-1 and PW-3, along with PW-2, were returning from Pamidi village. They were waiting for a ride at Miduthuru crossroads when they saw the deceased on his motorcycle. As the deceased was near Miduthuru around 6:00 PM, PW-4 requested the deceased to stop. After a brief conversation, the deceased proceeded further when a group of accused persons armed with hunting sickles emerged from nearby bushes and attacked him. PW-1 to PW-3 rushed to help the deceased but were threatened by the accused, who then fled. The deceased was taken to a hospital but was declared dead before admission. PW-1 to PW-3 supported the prosecution’s case, while PW-4 to PW-6 were declared hostile for not supporting the prosecution.

Timeline

Course of Proceedings

The Trial Court convicted accused nos. 1 to 4 and accused nos. 10 and 11 for the offences punishable under Sections 148 and 302 of the Indian Penal Code, 1860 (IPC). The Trial Court found that the charge under Section 120-B of the IPC was not proved against any accused. Accused nos. 6, 7, and 8 were acquitted. The co-accused in the case had preferred appeals, Criminal Appeal nos. 2130 and 2131 of 2011, which were disposed of by the Supreme Court on July 13, 2023, after the counsel for the appellants stated that they had been granted permanent remission and were not pressing the appeals. The appellant in this case was initially enlarged on bail but later decided to prosecute the appeal on merits instead of surrendering for consideration of permanent remission.

Legal Framework

The appellant was convicted under the following sections of the Indian Penal Code, 1860:

• Section 148, Indian Penal Code, 1860: This section deals with the offence of rioting, being armed with a deadly weapon.
• Section 302, Indian Penal Code, 1860: This section defines the punishment for murder.

Arguments

Appellant’s Submissions:

• The appellant’s counsel argued that PW-1 and PW-3, being brothers of the deceased, were interested witnesses and their testimony should not be considered as gospel truth.
• It was contended that PW-1 to PW-3 were chance witnesses, and their presence at the scene was not natural.
• The counsel pointed out that PW-4 to PW-6 did not mention the presence of the appellant at the time of the incident.
• The appellant’s counsel argued that the prosecution failed to establish a clear motive for the murder.
• It was submitted that if the testimony of PW-1 to PW-3 is discarded, there is no evidence against the appellant.

Respondent’s Submissions:

• The respondent-State supported the judgment of the Trial Court and the High Court, arguing that the evidence presented was sufficient to prove the appellant’s guilt.

Submissions Table

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues in the judgment. However, the core issue revolved around:

• Whether the testimony of the eyewitnesses (PW-1 to PW-3), who are related to the deceased, is reliable enough to sustain the conviction of the appellant.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following legal provisions:

• Section 148, Indian Penal Code, 1860: Regarding rioting with deadly weapons.
• Section 302, Indian Penal Code, 1860: Regarding the punishment for murder.

The Court did not specifically cite any case laws in this judgment.

Authorities Table

Judgment

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

How each authority was viewed by the Court?

The Court applied the provisions of Section 148 and Section 302 of the Indian Penal Code, 1860 to the facts of the case. The Court found that the evidence presented by the prosecution supported the charges under these sections. The Court did not cite any case laws, relying primarily on the factual evidence and witness testimonies.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the consistent and reliable testimony of the eyewitnesses, PW-1 to PW-3. The Court emphasized that the relationship of the witnesses to the deceased does not automatically discredit their testimony. The specific roles assigned to each accused by the witnesses, the recovery of blood-stained weapons, and the medical evidence corroborating the cause of death all weighed heavily in the Court’s decision. The lack of material contradictions in the cross-examination of the eyewitnesses further solidified the Court’s belief in their testimony.

Sentiment Analysis Table

Fact:Law Ratio

Logical Reasoning

The Court’s reasoning was based on the reliability of the eyewitness accounts, the consistency in their statements, and the corroborating medical and material evidence. The Court did not find any reason to discard the testimony of the eyewitnesses simply because they were related to the deceased. The Court stated, “Only because an eye witness is a member of the deceased’s family, per se, the evidence of such a witness cannot be discarded.” The Court also noted that “If the evidence of an eyewitness who is a close relative of the deceased is cogent, reliable and credible, it can always be relied upon.” The Court further emphasized that “Regarding the role of appellant-accused no.2, the evidence of PW-1 to PW-3 is consistent.”

Key Takeaways

• The testimony of eyewitnesses who are relatives of the victim can be considered reliable if it is consistent, cogent, and credible.
• The relationship of a witness to the victim does not automatically invalidate their testimony.
• Courts will assess the reliability of evidence based on its consistency and corroboration with other evidence, rather than solely on the witness’s relationship to the victim.
• This judgment reinforces the importance of direct eyewitness testimony in criminal cases, even when the witnesses are related to the victim.

Directions

The Supreme Court directed the appellant to surrender within one month to serve the remaining sentence. Additionally, the Court directed the respondent-State to consider the case of the appellant for grant of permanent remission, taking into account that the co-accused had been granted the same benefit. The State was directed to take a decision within two months from the date of the appellant’s surrender.

Development of Law

The ratio decidendi of this case is that the testimony of a related witness cannot be discarded solely based on their relationship with the victim. The court emphasized that if the testimony is cogent, reliable, and credible, it can be relied upon. This judgment does not introduce a new principle of law but reinforces the existing principle that the reliability of witness testimony should be assessed based on its inherent quality and consistency rather than the witness’s relationship with the victim.

Conclusion

The Supreme Court upheld the conviction of the appellant, Thatireddigari Maheswara Reddy, in a murder case, emphasizing that the testimony of eyewitnesses who are related to the victim can be considered reliable if it is consistent and credible. The Court’s decision underscores the importance of direct evidence and the need to assess the reliability of witness testimony based on its inherent quality rather than the witness’s relationship to the victim. The Court also directed the State to consider the appellant’s case for permanent remission, aligning it with the treatment of the co-accused.