A) ABSTRACT / HEADNOTE
This case examines the conviction and subsequent acquittal of the appellant, Ram Singh, for charges under Sections 301/302 IPC (culpable homicide amounting to murder) and Section 307 IPC (attempt to murder). The incident involved the alleged shooting of the deceased, Dulli, by the appellant during a personal altercation. However, key discrepancies in the evidence, such as non-recovery of the weapon, lack of ballistic analysis, and inconsistencies in witness testimonies, raised questions about the credibility of the prosecution’s case. The Supreme Court emphasized that when co-accused were acquitted based on identical evidence, conviction of the appellant on the same evidence violated the principle of parity. Consequently, the conviction was overturned, and the appellant was acquitted.
Keywords: Non-recovery of weapon, Ballistic evidence, Eyewitness reliability, Benefit of doubt, Acquittal.
B) CASE DETAILS
i) Judgement Cause Title:
Ram Singh v. The State of Uttar Pradesh
ii) Case Number:
Criminal Appeal No. 206 of 2024
iii) Judgement Date:
February 21, 2024
iv) Court:
Supreme Court of India
v) Quorum:
Hon’ble Justices Abhay S. Oka and Ujjal Bhuyan
vi) Author:
Justice Ujjal Bhuyan
vii) Citation:
[2024] 2 S.C.R. 668
viii) Legal Provisions Involved:
- Indian Penal Code, 1860 – Sections 301, 302, and 307.
- Code of Criminal Procedure, 1973 – Section 313.
ix) Judgments Overruled by the Case (if any):
None explicitly mentioned.
x) Case is Related to Law Subjects:
Criminal Law, Evidence Law.
C) INTRODUCTION AND BACKGROUND OF JUDGMENT
The case originated from an incident in Kanpur, Uttar Pradesh, involving personal animosity between the accused and the informant, PW-1, over local politics. The appellant allegedly fired a shot targeting PW-1, but it struck and killed his mother, Dulli. The trial court convicted the appellant under Sections 301/302 IPC for murder and Section 307 IPC for attempted murder. The co-accused, Lala Ram, was acquitted on the same evidence. This inconsistency in conviction prompted the appellant’s appeal to the Supreme Court.
D) FACTS OF THE CASE
- The incident occurred on August 19, 1982, at the informant’s house.
- PW-1 and his brother were seated near their mother, Dulli, in a courtyard.
- The appellant allegedly shot at PW-1, but the bullet struck Dulli, killing her instantly.
- The prosecution relied on testimonies of eyewitnesses and physical evidence, such as pellets recovered from the deceased.
- The weapon of crime (a country-made pistol) was never recovered.
- The trial court convicted the appellant, but the co-accused was acquitted based on identical evidence.
E) LEGAL ISSUES RAISED
- Whether the absence of ballistic evidence and weapon recovery undermined the prosecution’s case.
- Whether inconsistencies in eyewitness testimonies and omission of material witnesses affected the credibility of evidence.
- Whether convicting the appellant while acquitting the co-accused on the same evidence was legally sustainable.
F) PETITIONER/APPELLANT’S ARGUMENTS
- Eyewitness accounts were inconsistent and biased due to prior enmity.
- The non-recovery of the weapon of crime and lack of ballistic analysis raised doubts about the evidence’s reliability.
- Acquittal of the co-accused on identical evidence highlighted a lack of parity in judicial reasoning.
- There was insufficient evidence to prove guilt beyond reasonable doubt.
G) RESPONDENT’S ARGUMENTS
- Eyewitnesses consistently identified the appellant as the shooter.
- The absence of the weapon and ballistic report did not undermine credible direct evidence.
- The conviction was supported by circumstantial evidence and witness testimonies.
H) JUDGMENT
a. Ratio Decidendi
The Court held that when evidence against multiple accused is identical, conviction of one and acquittal of the other violates the principle of parity. Further, inconsistencies in prosecution evidence, coupled with omissions in witness examination and lack of material evidence like the weapon and ballistic report, rendered the case doubtful.
b. Obiter Dicta
The Court reiterated the principle that non-recovery of the weapon of crime and absence of ballistic analysis, though not fatal by themselves, could significantly weaken the prosecution’s case when combined with unreliable testimonies.
c. Guidelines
- Convictions must be based on evidence proving guilt beyond reasonable doubt.
- Courts must ensure consistent application of principles, especially in cases involving co-accused with identical charges.
- The credibility of eyewitness accounts must be scrutinized rigorously, particularly when there are allegations of bias.
I) CONCLUSION AND COMMENTS
The Court’s decision underscores the importance of consistent judicial reasoning and adherence to the principle of parity. The ruling also emphasizes that lapses in investigation, such as failure to recover the weapon or obtain ballistic evidence, combined with unreliable testimonies, can render convictions unsustainable.
J) REFERENCES
a. Important Cases Referred
- Javed Shaukat Ali Qureshi v. State of Gujarat, (2023) 9 SCC 164
- Munna Lal v. State of U.P., (2023) SCC Online SC 80
- Gurucharan Singh v. State of Punjab, AIR 1963 SC 340
- Sukhwant Singh v. State of Punjab, (1995) 3 SCC 367
- State of Punjab v. Jugraj Singh, (2002) 3 SCC 234
- Gulab v. State of U.P., (2022) 12 SCC 677
b. Important Statutes Referred
- Indian Penal Code, 1860: Sections 301, 302, 307
- Code of Criminal Procedure, 1973: Section 313
