A) ABSTRACT / HEADNOTE

The case involved a murder conviction under Section 302 IPC, where the appellant was alleged to have killed his roommate following a dispute. The evidence relied upon included eyewitness testimonies, extra-judicial confessions, and a dying declaration. The Supreme Court found significant lapses in the investigation and inconsistencies in witness testimonies. Consequently, the conviction was overturned. The judgment underscores the importance of procedural adherence and credible evidence in criminal trials.

Keywords: Extra-judicial confession, Dying declaration, Hostile witnesses, Procedural lapses, Indian Evidence Act.

B) CASE DETAILS

i) Judgment Cause Title: Lal Mohammad Manjur Ansari v. The State of Gujarat

ii) Case Number: Criminal Appeal No. 3524 of 2023

iii) Judgment Date: 08 July 2024

iv) Court: Supreme Court of India

v) Quorum: Hon’ble Justices Abhay S. Oka and Ujjal Bhuyan

vi) Author: Justice Abhay S. Oka

vii) Citation: [2024] 7 S.C.R. 41; 2024 INSC 475

viii) Legal Provisions Involved:

• Indian Penal Code, 1860: Section 302
• Indian Evidence Act, 1872: Sections 25, 26, and other provisions concerning confessions and dying declarations.

ix) Judgments Overruled: None explicitly mentioned.

x) Case is Related to: Criminal Law, Evidence Law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The appellant was convicted under Section 302 IPC for allegedly murdering his roommate following an argument. The prosecution relied on extra-judicial confessions, a dying declaration, and testimonies of eyewitnesses who turned hostile. Both the Trial Court and the High Court upheld the conviction. However, procedural deficiencies, dubious witness credibility, and evidentiary gaps prompted the Supreme Court to reassess the conviction.

D) FACTS OF THE CASE

1. Incident Date: 6th September 2004

   • The appellant and deceased shared a room rented from PW-3.
   • A dispute over playing music escalated, leading to the appellant allegedly attacking the deceased.

2. Prosecution Case:

   • Eyewitnesses (PW-3 to PW-9) provided contradictory accounts.
   • PW-19 claimed the appellant confessed to him over the phone and at a bus station.
   • PW-24 alleged the deceased identified the appellant in a dying declaration.

3. Defense Argument:

   • The appellant denied involvement and challenged the admissibility of evidence, citing procedural lapses and unreliable testimonies.

E) LEGAL ISSUES RAISED

1. Whether the extra-judicial confession was credible and admissible.
2. Whether the dying declaration met the evidentiary threshold.
3. Whether the hostile witnesses’ testimonies could establish guilt.
4. Whether procedural lapses undermined the prosecution’s case.

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Hostile Witnesses: The prosecution failed to corroborate their claims consistently, making their testimonies unreliable.
2. Extra-judicial Confession:
   • PW-19’s claim of receiving a phone call from the appellant lacked verification of call records.
   • PSI Mishra, a crucial witness to the alleged confession, was not examined.
3. Dying Declaration:
   • PW-24’s claim was inconsistent with other evidence.
   • PW-3 and PW-24 contradicted each other regarding the deceased’s ability to speak.
4. Custodial Irregularities:
   • Arrest details were unclear.
   • The absence of PSI Mishra’s testimony cast doubts on the narrative.

G) RESPONDENT’S ARGUMENTS

1. Eyewitness Accounts: The presence of the appellant at the crime scene and his actions (e.g., cleaning blood stains) implicated him.
2. Extra-judicial Confession: PW-19’s statement corroborated the appellant’s involvement.
3. Dying Declaration: The deceased explicitly named the appellant as the assailant before PW-24.
4. Circumstantial Evidence: The appellant’s actions post-incident supported the prosecution’s case.

H) JUDGMENT

a. Ratio Decidendi

The Supreme Court found that the prosecution failed to establish guilt beyond reasonable doubt due to procedural lapses and inconsistencies in evidence.

b. Obiter Dicta

The Court emphasized the necessity of thorough investigations and the critical role of witness credibility in criminal trials.

c. Guidelines

• Extra-judicial confessions must be corroborated by independent evidence.
• Dying declarations should meet strict admissibility standards.
• Prosecution must present all material witnesses.

I) CONCLUSION & COMMENTS

The judgment underscores the principles of fair trial and evidentiary rigor. By overturning the conviction, the Court upheld the presumption of innocence and emphasized the importance of procedural integrity.

J) REFERENCES

a. Important Cases Referred:

1. State of U.P. v. Boota Singh, AIR 1978 SC 1776: On extra-judicial confessions.
2. Pakala Narayana Swami v. Emperor, AIR 1939 PC 47: On the reliability of dying declarations.

b. Important Statutes Referred:

1. Indian Penal Code, 1860: Section 302.
2. Indian Evidence Act, 1872: Sections 25, 32 (Dying declarations).