Simplified Explanation of the Judgment
In a recent ruling dated August 20, 2024, the Hon'ble Patna High Court set aside the convictions of three men accused in a 2002 murder case from Malpur village under Maranchi Police Station, Patna district. The appellants had been sentenced to life imprisonment under Section 302 read with Section 34 of the IPC, and one of them also under Section 27 of the Arms Act.
The case revolved around the killing of a local Panchayat Samiti member. The prosecution alleged that the accused shot the victim over a past enmity stemming from a kidnapping case in which the deceased had played a mediating role. The trial court had convicted the accused based on circumstantial evidence.
However, the High Court found major procedural irregularities in the trial. Specifically, it held that the trial court wrongly considered the testimonies of two key prosecution witnesses (P.W.-1 and P.W.-2) who had not been re-examined in the presence of all accused after the amalgamation of separate trials. This violated Section 273 of the CrPC, which mandates that evidence must be recorded in the presence of the accused or their counsel. The Court emphasized that after merging trials, a fresh or de novo trial is required, and earlier statements cannot be used as evidence unless proper cross-examination is afforded.
The bench further observed that none of the witnesses, including the informant and the widow of the deceased, actually witnessed the murder. Their testimonies were either hearsay or based on post-event observations. The prosecution's entire case rested on circumstantial evidence that lacked a complete chain of events linking the accused directly to the crime.
Due to these reasons and following settled principles from Supreme Court rulings in cases based on circumstantial evidence, the High Court acquitted all three appellants.
Significance of the Judgment
This judgment underscores the importance of adhering to procedural fairness and the right to cross-examination in criminal trials. It reiterates that procedural lapses can render otherwise strong cases unconvincing in the eyes of the law. For common people, this ruling safeguards against wrongful conviction due to incomplete or irregular trial processes. It also reaffirms the judiciary's role in correcting errors at the trial stage.
Legal Issues Decided and Decision of the Court
Whether the trial court erred in using pre-amalgamation testimonies in the final judgment: Yes.
Whether the prosecution proved guilt beyond a reasonable doubt based on circumstantial evidence: No.
Final decision: Appeals allowed, conviction and sentence set aside, appellants acquitted.
Judgments Relied Upon or Cited by the Court:
Nasib Singh vs. State of Punjab, (2022) 2 SCC 89
Sharad Birdhichand Sarda vs. State of Maharashtra, (1984) 4 SCC 116
Padala Veera Reddy vs. State of A.P., 1989 Supp (2) SCC 706
Shailendra Rajdev Pasvan vs. State of Gujarat, (2020) 14 SCC 750
Neeraj Dutta vs. State (NCT of Delhi), (2023) 4 SCC 731
Pritinder Singh vs. State of Punjab, (2023) 7 SCC 727
Shankar vs. State of Maharashtra, 2023 SCC Online SC 268
Indrajit Das vs. State of Tripura, AIR Online 2023 SC 150
Nandu Singh vs. State of Chhattisgarh, 2022 SCC OnLine SC 1454
Shivaji Chintappa Patil vs. State of Maharashtra, (2021) 5 SCC 626
Case Title: Janardan Singh & Ors. vs. The State of Bihar
Case Numbers: Criminal Appeal (DB) No. 232 of 2010, 254 of 2010, and 422 of 2010
Citation(s): 2024(4) PLJR (605)
Coram and Names of Judges: Hon'ble Mr. Justice Ashutosh Kumar and Hon'ble Mr. Justice Jitendra Kumar
Advocates Appeared:
For the Appellants: Mr. Deepak Kumar Sinha, Advocate
For the State: Mr. D.K. Sinha, APP; Mr. A.K. Singh, APP
Link to the Judgment:-
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