A) Abstract / Headnote

The case concerns custodial torture and the death of a detainee, Jeeva, allegedly at the hands of police officers during detention at the Amraiwadi Police Station. The issue arose from conflicting evidence, including eyewitness testimonies and medical findings. The trial court convicted the officers under Section 302 IPC, a decision later modified to Section 304 Part I IPC by the High Court. On appeal, the Supreme Court found the medical evidence compelling, indicating the injuries could not have occurred as claimed by the prosecution. Consequently, the Supreme Court acquitted the accused.

Keywords: Custodial torture, custodial death, judicial custody, medical evidence, eyewitness credibility.

B) Case Details

i) Judgment Cause Title:
Vinod Jaswantray Vyas (Dead) Through Lrs. v. The State of Gujarat

ii) Case Number:
Criminal Appeal No. 2038 of 2017

iii) Judgment Date:
July 9, 2024

iv) Court:
Supreme Court of India

v) Quorum:
Justices B.R. Gavai and Sandeep Mehta

vi) Author:
Justice Sandeep Mehta

vii) Citation:
2024 INSC 490, [2024] 7 S.C.R. 365

viii) Legal Provisions Involved:

• Indian Penal Code, 1860 (Sections 302, 304 Part I, 114)
• Evidence Act, 1872

ix) Judgments Overruled by the Case:
Not explicitly overruled but revisited findings of lower courts.

x) Case Relates to:
Criminal Law and Evidence Law.

C) Introduction and Background of Judgment

The appeal challenged the High Court’s judgment that altered the conviction of two accused police officers for custodial torture resulting in the death of Jeeva. The case had its origins in allegations of police brutality at the Amraiwadi Police Station, with the trial court convicting the accused under Section 302 IPC. The High Court modified the conviction to Section 304 Part I IPC. Upon further appeal, the Supreme Court reviewed the evidentiary record, including eyewitness accounts and medical opinions, before delivering its verdict.

D) Facts of the Case

Jeeva surrendered at the Amraiwadi Police Station on June 10, 1992, in the company of his sisters (PW-1 and PW-2) and an advocate. He was accused in a criminal case (CR No. 555/92). During his custody, he was allegedly assaulted by police officers Vinod Jaswantray Vyas (A1) and Chinubhai Govindbhai Patel (A2), leading to severe injuries.

The prosecution alleged that these injuries caused Jeeva’s death in Sabarmati Central Jail on June 12, 1992. A post-mortem report indicated multiple injuries, including fractures, internal bleeding, and ruptured organs. Eyewitness testimonies by PW-1, PW-2, and a co-detainee (PW-3) supported the prosecution’s narrative. The trial court convicted A1 and A2 for murder. The High Court later toned down the conviction to culpable homicide not amounting to murder (Section 304 Part I IPC).

E) Legal Issues Raised

1. Whether the prosecution proved beyond reasonable doubt that Jeeva’s death resulted from custodial assault by the accused.
2. Whether the High Court erred in modifying the conviction to Section 304 Part I IPC.
3. The credibility of medical evidence versus eyewitness accounts.
4. The role of procedural lapses and delayed complaints in determining the accused’s culpability.

F) Petitioner/Appellant’s Arguments

1. The prosecution’s evidence lacked credibility due to contradictions between medical findings and eyewitness accounts.
2. Delay in filing complaints cast doubt on the allegations.
3. Medical evidence suggested the injuries were fresh and likely occurred within six hours of death, contradicting claims of custodial assault.
4. Jeeva showed no visible signs of distress when presented before the Magistrate or senior officers, undermining claims of assault.
5. The prosecution failed to examine material witnesses, including the advocate who accompanied Jeeva.

G) Respondent’s Arguments

1. Prosecution witnesses were credible, and their testimonies were consistent with the alleged custodial torture.
2. Delays in filing complaints were explained by fear of police reprisal.
3. The trial court and High Court rightly appreciated evidence to hold the accused guilty of custodial torture.
4. Medical evidence corroborated the timing and severity of the injuries inflicted during custody.

H) Related Legal Provisions

Indian Penal Code, 1860:

• Section 302: Murder
• Section 304 Part I: Culpable homicide not amounting to murder
• Section 114: Abetment

Evidence Act, 1872:

• Rules of admissibility and credibility of evidence.

I) Judgment

a) Ratio Decidendi

The Supreme Court emphasized the primacy of medical evidence over inconsistent eyewitness accounts. The medical jurist’s testimony demonstrated that Jeeva’s injuries were fresh and likely inflicted within hours of his death, contradicting claims of police brutality during his initial custody. The prosecution failed to bridge this contradiction, resulting in an acquittal.

b) Obiter Dicta

The court criticized procedural lapses, including delayed complaints and failure to examine key witnesses like the advocate. It reiterated the need for corroborative evidence in custodial torture cases to prevent misuse of judicial process.

c) Guidelines

1. Courts must weigh medical evidence heavily when it contradicts eyewitness testimony.
2. Procedural integrity and timely complaints are critical in custodial violence cases.
3. Law enforcement officials should adhere to transparent procedures to avoid allegations of brutality.

J) Conclusion and Comments

The judgment highlights the need for robust and credible evidence to sustain convictions in custodial torture cases. It underscores the importance of reconciling medical and ocular evidence to deliver justice.

K) References

1. Lahu Kamlakar Patil v. State of Maharashtra, [2013] 6 SCC 417.
2. Shivasharanappa v. State of Karnataka, [2013] 5 SCC 705.
3. Narendrasinh Keshubhai Zala v. State of Gujarat, [2023] 4 SCALE 478.
4. Chunthuram v. State of Chhattisgarh, (2020) 10 SCC 733.
5. Evidence Act, 1872: Sections on admissibility and proof of evidence.