Case Note & Summary
The appellant, Ranjeet Singh, was convicted under Section 302 of the Indian Penal Code, 1860 for the murder of Devnath/Deonath on 15.01.2010. The trial court sentenced him to life imprisonment and a fine of Rs. 1,000/-. The High Court of Chhattisgarh at Bilaspur upheld the conviction and sentence in Criminal Appeal No. 279 of 2017. The appellant then appealed to the Supreme Court. The prosecution's case relied heavily on three minor eyewitnesses: Anita (PW-13), Meena (PW-14), and Lali/Lalo (PW-15). The FIR was registered at Police Station Ramanujnagar, District Surguja, Chhattisgarh on 15.01.2010 at 14:30 hrs based on the complaint of Vikas Kumar (PW-1), son of the deceased. The Supreme Court, after hearing the parties and examining the trial court records, found that the three minor witnesses were not credible eyewitnesses. The Court noted that Anita and Meena are sisters, and Lali/Lalo is the granddaughter of the deceased. The Court was not satisfied that these witnesses were present at the occurrence. Consequently, the Court held that the conviction was not sustainable and allowed the appeal, setting aside the conviction and sentence. The appellant was acquitted and ordered to be released forthwith unless required in any other case.
Headnote
A) Criminal Law - Murder - Section 302 Indian Penal Code, 1860 - Eyewitness Testimony - Minor Witnesses - The Supreme Court examined the credibility of three minor witnesses (PW-13, PW-14, PW-15) who claimed to have witnessed the murder. The Court found their testimonies unreliable as they were not present at the scene and their statements were inconsistent. Held that the conviction cannot be sustained and the appellant is entitled to acquittal. (Paras 1-2)
Issue of Consideration
Whether the conviction of the appellant under Section 302 IPC based on the testimony of three minor eyewitnesses is sustainable.
Final Decision
Appeal allowed. Conviction and sentence set aside. Appellant acquitted and ordered to be released forthwith unless required in any other case.
Law Points
- Conviction based on unreliable eyewitness testimony
- Minor witnesses credibility
- Section 302 IPC
- Benefit of doubt
