Supreme Court Acquits Appellant in Stepmother's Murder Case. Conviction overturned due to unreliable witness testimonies and insufficient evidence.

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Case Note & Summary

The appellant was convicted by the Sessions Court for the murder of his stepmother under Section 302 of the IPC and sentenced to life imprisonment. The High Court dismissed his appeal. The prosecution's case was based on a land dispute, eyewitness testimony, and an extra-judicial confession. The Supreme Court, upon review, found inconsistencies in the prosecution's evidence, particularly the testimonies of key witnesses and the absence of injury marks on the deceased. The Supreme Court acquitted the appellant, stating that his guilt was not proven beyond a reasonable doubt.

Conviction and Appeal Conviction by Sessions Court: The appellant was convicted for murder and sentenced to life imprisonment. High Court's Decision: The High Court dismissed the appellant's appeal. Factual Aspect Prosecution's Case: Appellant assaulted and drowned his stepmother due to a land dispute. Key Witnesses: PW-1: Village officer who reported an extra-judicial confession. PW-5: Deceased’s brother who allegedly saw the appellant dragging the deceased. Submissions Appellant's Counsel: Questioned the credibility of PW-1’s testimony and highlighted the lack of corroborative evidence. Argued that the death was due to drowning, not necessarily homicidal. State's Counsel: Defended the reliance on PW-1’s partial testimony and the evidence of PW-5. Consideration of Submissions Review of Evidence: Postmortem report showed death by drowning, with no injury marks on the body. The prosecution’s failure to seek an expert opinion and the absence of key witnesses undermined their case. Extra-Judicial Confession: Considered a weak form of evidence requiring corroboration. The court found PW-1’s testimony unreliable due to inconsistencies. Testimonies and Witnesses PW-1’s Testimony: Inconsistent and unreliable regarding the extra-judicial confession. PW-5’s Testimony: Contradicted by the lack of injuries on the deceased and the non-examination of crucial witnesses like Lakhan. Conclusion Insufficient Evidence: The evidence presented did not prove the appellant’s guilt beyond a reasonable doubt. Acquittal: The appellant was acquitted, and the previous judgments were set aside.

Issue of Consideration: RATNU YADAV VERSUS THE STATE OF CHHATTISGARH

2024 LawText (SC) (7) 97

CRIMINAL APPEAL NO. 1635 OF 2018

2024-07-09

(Abhay S. Oka J. And Rajesh Bindal J. )

RATNU YADAV

THE STATE OF CHHATTISGARH

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