A) ABSTRACT / HEADNOTE

The Supreme Court reversed the High Court’s acquittal of the main accused, Gurpreet Singh, convicted under Section 302 IPC for murdering his former mother-in-law, Amarjit Kaur, driven by revenge for his failed marriage. The trial court’s reliance on eyewitness testimony and forensic evidence was reinstated, as the prosecution proved guilt beyond a reasonable doubt. However, the Court upheld the High Court’s acquittal of the co-accused, citing insufficient evidence and plausible doubts about their involvement.

Keywords:

Murder, Acquittal, Natural Witnesses, Motive, Prompt FIR, Extraordinary Jurisdiction, Recovery of Weapon.

B) CASE DETAILS

i) Judgement Cause Title: State of Punjab v. Gurpreet Singh & Ors.

ii) Case Number: Criminal Appeal Nos. 664-665 of 2024.

iii) Judgement Date: 06 February 2024.

iv) Court: Supreme Court of India.

v) Quorum: Surya Kant and K.V. Viswanathan, JJ.

vi) Author: Surya Kant, J.

vii) Citation: [2024] 2 S.C.R. 1039.

viii) Legal Provisions Involved: Section 302 IPC, Section 34 IPC, and Sections 25, 27, 54, and 59 of the Arms Act, 1959; Article 136 of the Constitution of India.

ix) Judgments Overruled by the Case (if any): High Court judgment acquitting Gurpreet Singh under Section 302 IPC.

x) Case is Related to: Criminal Law.

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case arose from the murder of Amarjit Kaur, allegedly orchestrated by her former son-in-law, Gurpreet Singh, and others. The motive stemmed from Gurpreet’s resentment over his failed marriage, for which he blamed the deceased. The trial court convicted all the accused based on eyewitness accounts and corroborating evidence. The High Court, however, acquitted them, raising doubts about witness reliability and the lack of a test identification parade. The Supreme Court, in this appeal, addressed the validity of the acquittals.

D) FACTS OF THE CASE

1. Amarjit Kaur was murdered at her residence by Gurpreet Singh and others on July 18, 2012.
2. Gurpreet blamed her for his divorce and the collapse of his plans to settle abroad.
3. The complainant, Amarjit’s husband, and their daughter were eyewitnesses to the crime.
4. A firearm was recovered from Gurpreet Singh’s disclosure, and forensic evidence corroborated the eyewitness testimonies.
5. The trial court convicted Gurpreet under Section 302 IPC, while co-accused were convicted under Section 302/34 IPC.
6. The High Court acquitted all accused, citing inconsistencies in witness statements and lack of direct evidence against co-accused.

E) LEGAL ISSUES RAISED

1. Whether the High Court was justified in acquitting Gurpreet Singh despite overwhelming evidence.
2. Whether the prosecution’s evidence sufficiently established the guilt of the co-accused.
3. Whether the Supreme Court should interfere with the High Court’s acquittal under Article 136 of the Constitution.

F) PETITIONER / APPELLANT’S ARGUMENTS

1. The prosecution established a clear motive for Gurpreet Singh’s involvement in the murder.
2. The eyewitness testimonies were consistent, corroborated by forensic evidence.
3. The High Court’s reasoning was flawed, as it disregarded prompt FIR lodging and recovery of the weapon.
4. The lack of a test identification parade did not negate the reliability of the witnesses.
5. The High Court erred in extending the benefit of the doubt to the co-accused without substantiating its findings.

G) RESPONDENT’S ARGUMENTS

1. The High Court correctly questioned the reliability of the eyewitnesses.
2. The testimonies were contradictory, particularly regarding the identification of co-accused.
3. The lack of neighborhood witnesses cast doubt on the prosecution’s case.
4. Article 136 jurisdiction should not be invoked to interfere with the High Court’s findings unless there was a grave miscarriage of justice.

H) JUDGEMENT

a. Ratio Decidendi:

1. The Supreme Court reinstated Gurpreet Singh’s conviction under Section 302 IPC, holding that the evidence unequivocally established his guilt.
2. The prosecution’s version was credible, as supported by prompt FIR lodging and recovery of the murder weapon.
3. The High Court’s findings were perverse and a misreading of evidence.
4. The acquittal of the co-accused was upheld due to reasonable doubts about their involvement.

b. Obiter Dicta (if any): The Court emphasized the importance of prompt FIR lodging in enhancing prosecution credibility.

c. Guidelines:

1. Appellate courts must not lightly disregard trial court findings unless there is strong evidence of error.
2. Circumstantial evidence, corroborated by credible witnesses, is sufficient for conviction under Section 302 IPC.

I) CONCLUSION & COMMENTS

The judgment underscores the delicate balance between upholding the presumption of innocence and addressing gross miscarriage of justice. The Supreme Court’s nuanced approach in distinguishing the culpability of the main accused and the co-accused reaffirms the importance of evidence-based adjudication.

J) REFERENCES

a. Important Cases Referred:

1. State of Karnataka v. J. Jayalalitha (2017) 6 SCC 263.
2. Rajesh Prasad v. State of Bihar (2022) 3 SCC 471.
3. Thotia Manohar v. State of Andhra Pradesh (2012) SCC 7 723.
4. Nand Lal v. State of Chhattisgarh (2023) 10 SCC 470.
5. Thulia Kali v. State of Tamil Nadu (1972) 3 SCC 393.

b. Important Statutes Referred:

1. Indian Penal Code, 1860 – Section 302, Section 34.
2. Arms Act, 1959 – Sections 25, 27, 54, and 59.
3. Constitution of India – Article 136.