Case Note & Summary
The appeal arose from a judgment of the High Court of Punjab and Haryana at Chandigarh dated 05.12.2019, which acquitted four respondents of charges under Section 302 read with Section 34 of the Indian Penal Code, 1860, overturning their conviction by the Trial Court. The case involved the murder of Amarjit Kaur on 18.07.2012, with FIR No. 100 registered under Sections 302 and 34 IPC and Sections 25, 27, 54, and 59 of the Arms Act, 1959. The prosecution's case relied on eyewitness testimonies from Gursewak Singh (P.W.2), the complainant and husband of the deceased, and Harmandeep Kaur (P.W.3), their daughter, who alleged that Gurpreet Singh, the main accused, shot the deceased due to enmity stemming from his divorce from their elder daughter. The Trial Court convicted the accused based on these testimonies, but the High Court acquitted them, citing discrepancies such as the complainant's presence at the scene, delayed naming of co-accused, and doubts about the daughter's whereabouts. The State of Punjab appealed to the Supreme Court. The core legal issues were whether the Supreme Court should interfere under Article 136 of the Constitution and whether the acquittal was sustainable. The State argued that the High Court erred in disbelieving credible eyewitnesses, while the respondents contended that interference was unwarranted given the presumption of innocence. The Court analyzed the scope of interference, citing precedents like State of Karnataka v. J. Jayalalitha and Rajesh Prasad v. State of Bihar, which establish that intervention is justified when the High Court's approach is perverse or leads to a miscarriage of justice. The Court found that the High Court's reasoning was flawed, as the discrepancies were minor and did not undermine the eyewitness testimonies, which were consistent and corroborated by medical evidence. The Court held that the acquittal was unsustainable and restored the conviction, emphasizing the need to prevent injustice. The decision favored the prosecution, with the Court allowing the appeal and setting aside the High Court's acquittal.
Headnote
A) Constitutional Law - Supreme Court Jurisdiction - Article 136 of the Constitution of India - Scope of Interference in Acquittal Orders - The Supreme Court outlined principles for interfering with acquittal orders under Article 136, emphasizing that intervention is warranted when the High Court's approach is perverse, based on irrelevant grounds, or leads to a miscarriage of justice, and the Court must not shy away from preventing injustice (Paras 15-18). B) Criminal Law - Evidence - Eyewitness Testimony - Credibility and Corroboration - The Court held that the testimonies of the complainant and his daughter were credible and corroborated by medical evidence, and discrepancies highlighted by the High Court were minor and did not undermine their reliability, restoring the conviction (Paras 20-22).
Issue of Consideration
Whether a case is made out for interference by the Supreme Court under Article 136 of the Constitution of India, and whether the acquittal of the respondents is sustainable
Final Decision
The Supreme Court allowed the appeal, set aside the High Court's acquittal, and restored the conviction of the respondents under Section 302 read with Section 34 of the Indian Penal Code, 1860.
Law Points
- Presumption of innocence restored upon acquittal
- scope of interference under Article 136 of the Constitution of India
- principles for overturning acquittal orders
- credibility of eyewitness testimony
- burden of proof in criminal cases
