In a significant legal development, the Patna High Court delivered a judgment on November 9, 2023, acquitting all the accused individuals in connection with a murder case that originated from Majorganj Police Station in Sitamarhi district of Bihar. The case, registered as P.S. Case No. 13 of 2015, involved three separate criminal appeals brought before a Division Bench comprising Honourable Mr. Justice Ashutosh Kumar and Honourable Mr. Justice Alok Kumar Pandey. The appeals, namely Criminal Appeal (DB) No. 1050 of 2018, Criminal Appeal (DB) No. 806 of 2018, and Criminal Appeal (DB) No. 903 of 2018, were filed by Murari Singh, Shashi Bhushan Singh, Govind Singh, and Mukesh Singh @ Mukesh Kumar @ Mukesh Kumar Singh, respectively, against the State of Bihar.
The core issue before the High Court was to examine the correctness and legality of the judgment of conviction and the order of sentence passed by the Trial Court against the appellants. After a thorough examination of the evidence and circumstances presented, the Division Bench concluded that the prosecution had failed to establish the guilt of the accused beyond a reasonable doubt. Consequently, the High Court overturned the Trial Court's decision and acquitted all the appellants of the charges leveled against them.
Background of the Case
The case stemmed from an incident that led to the registration of P.S. Case No. 13 of 2015 at Majorganj Police Station in Sitamarhi. While the specifics of the initial complaint and the identity of the victim are not explicitly detailed in the provided excerpts, the fact that the Trial Court had previously convicted the appellants indicates that the case involved a serious offense, likely murder, given the subsequent acquittal and the nature of criminal appeals.
The appellants, Murari Singh, Shashi Bhushan Singh (father of Murari and Govind Singh), Govind Singh, and Mukesh Singh, were all residents of the Sitamarhi district. They were found guilty by the Trial Court, leading them to file separate appeals before the Patna High Court challenging their conviction and sentence.
Arguments Presented Before the High Court
During the hearing of the appeals, the appellants were represented by a team of advocates including Mr. Ajay Kumar Thakur, Ms. Kiran Kumari, Mr. Ritwik Thakur, Ms. Vaishnavi Singh, Mr. Pravin Kumar, and Mr. Ritwaj Raman. They likely argued that the prosecution had failed to provide sufficient and credible evidence to link the appellants to the crime. Their arguments would have centered on inconsistencies in the prosecution's case, lack of reliable witnesses, and the absence of conclusive evidence proving their involvement in the alleged murder.
On the other hand, the State of Bihar was represented by Mr. Dilip Kumar Sinha, the Additional Public Prosecutor (APP). The APP would have argued in favor of upholding the Trial Court's judgment, asserting that the prosecution had successfully proven the guilt of the accused based on the evidence presented during the trial.
The High Court's Observations and Decision
After carefully considering the submissions from both sides and perusing the records of the case, the Division Bench of the Patna High Court expressed its reservations about the prosecution's case. In paragraph 39 of the judgment, the Court explicitly stated that they were "persuaded to give benefit of doubt to all the appellants." This indicates that the Court found significant weaknesses or inconsistencies in the evidence presented by the prosecution, which prevented them from concluding with certainty that the appellants were indeed guilty of the crime.
The Court further elaborated on their reasoning by stating that "the murder might have taken place in some other transaction, at some other time, in a different manner." This crucial observation suggests that the High Court believed that the prosecution's narrative of the events leading to the murder was not sufficiently convincing or supported by concrete evidence. The possibility of alternative scenarios that were not adequately addressed by the prosecution likely played a significant role in the Court's decision to grant the benefit of doubt to the accused.
Based on these considerations, the High Court proceeded to set aside the judgment of conviction and the order of sentence passed by the Trial Court. Paragraph 40 of the judgment clearly states, "For the afore-noted reasons, we set-side the judgment of conviction and order of sentence, referred to above, and acquit the appellants, above-named, of
Implications of the Judgment
The High Court's decision to acquit all the accused has several important implications:
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Benefit of Doubt: The judgment underscores the fundamental principle of criminal jurisprudence that an accused person is presumed innocent until proven guilty beyond a reasonable doubt. If the prosecution fails to meet this high threshold, the accused is entitled to an acquittal. In this case, the High Court clearly felt that the prosecution's evidence fell short of establishing the guilt of the appellants beyond a reasonable doubt.
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Scrutiny of Trial Court Decisions: The case highlights the appellate jurisdiction of the High Court and its role in reviewing and, if necessary, correcting the decisions of the lower courts. The fact that the High Court overturned the Trial Court's conviction indicates a divergence in the assessment of the evidence and the application of legal principles.
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Liberty of the Accused: Following the acquittal, the High Court issued specific directions regarding the liberty of the appellants. Paragraph 41 notes that all appellants except Murari Singh were already on bail. For them, the Court ordered the cancellation of their liabilities under the bail bonds (paragraph 42). As for Murari Singh, who was stated to be in custody, the Court directed that he be set at liberty forthwith, provided he was not required in any other case (paragraph 43). This ensures the immediate release of the acquitted individuals from any legal restraint related to this particular case.
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Finality at the High Court Level: With the High Court allowing all the appeals (paragraph 44), the judgment represents a significant stage in the legal process. Unless the State of Bihar chooses to appeal this decision to the Supreme Court of India, the acquittal stands as the final verdict in this case at the High Court level.
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Procedural Directions: The Court also issued directions for the dispatch of the judgment copy to the Superintendent of the concerned Jail for compliance and record (paragraph 45). Additionally, the records of the appeals were ordered to be returned to the Trial Court (paragraph 46). Any pending interlocutory applications in the appeals were also disposed of (paragraph 47). These procedural directives ensure the smooth implementation of the High Court's order.
Conclusion
The acquittal of all the accused in the Majorganj murder case by the Patna High Court serves as a reminder of the stringent standards of proof required in criminal trials. The High Court's decision, based on the benefit of doubt, indicates that the prosecution's evidence was not compelling enough to conclusively establish the guilt of Murari Singh, Shashi Bhushan Singh, Govind Singh, and Mukesh Singh. While the judgment brings relief to the appellants and their families, it may also raise questions about the effectiveness of the initial investigation and prosecution of the case. The possibility that the "murder might have taken place in some other transaction, at some other time, in a different manner" leaves the underlying crime unresolved, at least based on the evidence presented in this particular case. The judgment underscores the judiciary's commitment to upholding the principles of justice and ensuring that no individual is convicted without sufficient legal and factual basis.
Read the full judgement Below;
https://patnahighcourt.gov.in/viewjudgment/NSMxMDUwIzIwMTgjMSNO-lxiOLBzfzO0=
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