RATNU YADAV vs. THE STATE OF CHHATTISGARH

Case Analysis

RATNU YADAV vs. THE STATE OF CHHATTISGARH

November 27, 2024

A) ABSTRACT / HEADNOTE

This judgment pertains to Ratnu Yadav v. The State of Chhattisgarh, a criminal appeal where the Supreme Court examined the legality of the appellant’s conviction under Section 302 of the Indian Penal Code, 1860 for the alleged murder of his stepmother. The primary evidence included an extra-judicial confession made to PW-1 and the last seen together testimony by PW-5. The Court scrutinized the evidentiary value of these submissions and found procedural lapses, lack of credible corroboration, and inconsistencies. The absence of material witnesses and injury marks on the deceased further raised doubts about the prosecution’s case. Consequently, the Supreme Court acquitted the appellant, citing failure to prove guilt beyond a reasonable doubt.

Keywords: Extra-judicial confession, Last seen together, Section 302 IPC, Beyond reasonable doubt, Procedural lapses.

B) CASE DETAILS

i) Judgment Cause Title:
Ratnu Yadav v. The State of Chhattisgarh

ii) Case Number:
Criminal Appeal No. 1635 of 2018

iii) Judgment Date:
July 9, 2024

iv) Court:
Supreme Court of India

v) Quorum:
Justice Abhay S. Oka and Justice Rajesh Bindal

vi) Author:
Justice Abhay S. Oka

vii) Citation:
[2024] 7 S.C.R. 466: 2024 INSC 487

viii) Legal Provisions Involved:

Section 302, Indian Penal Code, 1860
Section 161, Code of Criminal Procedure, 1973
Section 145, Indian Evidence Act, 1872

ix) Judgments Overruled by the Case (if any):
None explicitly mentioned.

x) Case is Related to which Law Subjects:
Criminal Law, Evidence Law, and Procedural Law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The appellant was convicted for murdering his stepmother by allegedly drowning her in a village pond. The prosecution’s case relied on an extra-judicial confession made to the village officer (PW-1) and testimony of the deceased’s brother (PW-5) who claimed to have seen the appellant dragging the victim by her hair to the pond. Both the Sessions Court and High Court accepted these submissions and sentenced the appellant to life imprisonment. The Supreme Court reviewed this conviction under the appellate jurisdiction.

D) FACTS OF THE CASE

The appellant allegedly murdered his stepmother, Smt. Hemwati Bai, following a dispute over land ownership.
It was claimed that he assaulted her, dragged her by her hair to the village pond, and drowned her by submerging her head in water.
The prosecution’s evidence included:
- Extra-judicial confession before PW-1, the village officer.
- Testimony of PW-5, the deceased’s brother, who allegedly witnessed the act.
The postmortem report confirmed drowning but did not conclusively establish homicidal death.
Material witnesses, including a neighbor who allegedly intervened, were not examined.
The prosecution also failed to prove the correlation between the pond water and the water found in the deceased’s lungs.

E) LEGAL ISSUES RAISED

i) Whether the extra-judicial confession of the appellant to PW-1 was reliable?
ii) Whether the testimony of PW-5 was sufficient to prove the appellant’s guilt?
iii) Whether procedural lapses in examining witnesses and evidence undermined the case?
iv) Whether the guilt of the appellant was established beyond reasonable doubt?

F) PETITIONER/APPELLANT’S ARGUMENTS

i) The appellant’s counsel argued that the extra-judicial confession to PW-1 was inadmissible as PW-1’s examination-in-chief and cross-examination contained contradictory statements.

ii) PW-1, a hostile witness, was not confronted with prior statements under Section 161, CrPC, violating Section 145, Evidence Act.

iii) PW-5’s testimony was inconsistent, and the absence of corroborating witnesses weakened the prosecution’s case.

iv) The postmortem report indicated drowning but did not confirm whether it was homicidal or accidental.

v) No injuries were found on the deceased’s body, making it improbable that she was dragged by her hair.

vi) Material witnesses such as neighbors and onlookers were not examined, which raised adverse inferences under Section 114(g), Evidence Act.

G) RESPONDENT’S ARGUMENTS

i) The prosecution argued that PW-1’s cross-examination established the appellant’s confession.

ii) Evidence of PW-5 proved the appellant’s presence at the scene and the act of dragging the deceased.

iii) The prosecution asserted that drowning in the pond was homicidal based on circumstantial evidence.

iv) The absence of material witnesses did not discredit the testimony of PW-1 and PW-5, which independently substantiated the case.

H) RELATED LEGAL PROVISIONS

i) Section 302, IPC: Punishment for murder.
ii) Section 161, CrPC: Statement to police during investigation.
iii) Section 145, Evidence Act: Cross-examination of witnesses on prior inconsistent statements.
iv) Section 114(g), Evidence Act: Adverse inference from non-production of witnesses.

I) JUDGMENT

a. Ratio Decidendi
The Court emphasized that the prosecution failed to prove guilt beyond reasonable doubt. The reliance on an extra-judicial confession and weak circumstantial evidence was insufficient.

b. Obiter Dicta
The Court highlighted the importance of corroborative evidence for extra-judicial confessions and the need for thorough cross-examination in line with Section 145, Evidence Act.

c. Guidelines

Extra-judicial confessions must be corroborated by strong evidence.
Hostile witnesses should be examined carefully with prior statements.
Non-examination of material witnesses can lead to adverse inferences.

J) REFERENCES

a. Important Cases Referred

Devi Lal v. State of Rajasthan, [2019] 1 SCR 168; (2019) 19 SCC 447.
Nikhil Chandra Mondal v. State of West Bengal, [2023] 2 SCR 20; (2023) 6 SCC 605.

b. Important Statutes Referred