Summary of the Judgment
Case Name: Saheb, s/o Maroti Bhumre etc. v. The State of Maharashtra
Date: 18th September 2024
Court: Supreme Court of India
Judges: Honorable Justice Sanjay Kumar and Honorable Justice Aravind Kumar
Acts and Sections Involved:
Sections 148, 302, and 324 read with Section 149 of the Indian Penal Code (IPC)
Section 374 of the Criminal Procedure Code (Cr.P.C.)
Cited Judgements:
Narain vs. State of Madhya Pradesh (2004) 2 SCC 455
Introduction
In a significant decision, the Honorable Supreme Court of India recently acquitted two individuals who had been convicted for their alleged involvement in a brutal murder, underscoring the fundamental legal principle that conviction must rest on proof beyond reasonable doubt. The case, Saheb, s/o Maroti Bhumre & Anr. v. The State of Maharashtra, centred around the murder of Madhavrao Krishnaji Gabare, which was purportedly motivated by political rivalry. The appellants, who had been sentenced to lengthy imprisonment by the Trial Court, challenged their convictions, contending that the evidence presented, primarily the testimony of a single eyewitness, was insufficient and unreliable.
Background of the Case
The appellants in this case, Saheb s/o Maroti Bhumre (Accused No. 3) and Sitaram Pandurang Gabare (Accused No. 5), were convicted by the Additional Sessions Judge, Basmathnagar, for the murder of Madhavrao Krishnaji Gabare. A total of 22 individuals were charged with the offence, but only 9 were held guilty of offences under Sections 148, 302, and 324 of the Indian Penal Code (IPC), read with Section 149. The conviction of the appellants was sustained by the Bombay High Court, leading to this appeal before the Supreme Court of India.
The incident in question took place on 8th April 2006 in the village of Singi, Maharashtra, where Madhavrao Gabare and his family were attacked, allegedly due to political rivalry. The prosecution's case primarily relied on the testimony of Janakibai Gabare, the widow of the deceased, who identified the appellants as key perpetrators of the attack.
Key Legal Issues
The appeal raised the following important legal questions:
Credibility of the Sole Witness: The central question revolved around the reliability of the sole key witness, Janakibai (PW-1), whose testimony formed the crux of the prosecution's case. The inconsistencies in her statements, both during her initial complaint and subsequent deposition before the court, were crucial in determining the appellants' guilt.
Benefit of Reasonable Doubt: The defence argued that given the contradictions in the testimony of the key witness and the absence of corroborating evidence, the appellants were entitled to the benefit of doubt.
Findings of the Court
The Honorable Supreme Court, after a thorough examination of the evidence, primarily focused on the inconsistencies in the testimony of Janakibai (PW-1). Her deposition before the Trial Court significantly deviated from her original complaint recorded in the hospital after the incident. This raised serious concerns about her reliability as the sole eyewitness to the incident.
The Honorable Court noted:
“Juxtaposition of her deposition before the Trial Court and her initial complaint clearly demonstrate that Janakibai (PW-1) embellished her narration of how the attack occurred, resulting in a lot of inconsistencies.”
These discrepancies were particularly evident in her description of how the assault unfolded, as well as in the number and identity of the attackers. The prosecution failed to substantiate its claims through corroborative evidence, such as testimony from other key witnesses, including Annapurnabai, the deceased’s daughter-in-law, who was not even examined by the prosecution despite being present during the attack.
The Court also highlighted the improbability of clear identification under the conditions of a power cut. Although Janakibai stated that there was sufficient moonlight, no other evidence supported her claim that it was bright enough to identify the attackers with certainty. The absence of clarity in the conditions under which the incident occurred led the Court to express doubt about the precision of her testimony:
“It is difficult to believe that, in the melee that ensued, any person who was under attack would be in a position to identify, clearly and with certainty, as to who was assaulting whom and with what weapon.”
Application of Legal Principles
The Supreme Court also applied the well-established legal principle of “Falsus in uno, falsus in omnibus” (false in one thing, false in everything). Although this principle is not a rule of law in India, it serves as a cautionary tool for courts to approach inconsistent testimony with suspicion. In the present case, the Court found it difficult to separate truth from falsehood in the testimony of Janakibai, which was riddled with contradictions.
“Though the maxim ‘Falsus in uno, falsus in omnibus’ is only a rule of caution and has not assumed the status of a rule of law in the Indian context, an attempt must be made to separate truth from falsehood and where such separation is impossible, there cannot be a conviction.”
Acquittal and Benefit of Doubt
Based on the principle that the prosecution must prove its case beyond a reasonable doubt, the Supreme Court found that the evidence on record did not meet the necessary threshold for conviction. The inconsistencies in the key witness's testimony, combined with the failure to examine crucial witnesses, created enough room for reasonable doubt in the case. The Court concluded:
“All that the defence needs to establish is the existence of reasonable doubt for the accused to be given the benefit thereof.”
Accordingly, the appellants were acquitted of the charges under Sections 148 and 302 of the IPC, read with Section 149.
Sentencing and Incarceration
A significant aspect of the judgment was the appellants' long period of incarceration, which spanned over 10 years. While the appellants were released on bail by an earlier order of the Court in 2016, they had already served a substantial portion of their sentences by that time. The Court took note of this prolonged incarceration, which further influenced its decision to acquit the appellants.
The Court also ordered that the appellants’ bail bonds and sureties be discharged and directed the refund of any fines paid by them. The judgment underscored the importance of ensuring that convictions are based on solid and reliable evidence, especially in cases involving serious offences like murder.
Conclusion
This judgement reaffirms the principle that conviction in a criminal case must rest on credible and reliable evidence. The Supreme Court's decision to acquit the appellants on the basis of reasonable doubt underscores the judiciary's role in safeguarding the rights of individuals against wrongful conviction. The case serves as a reminder of the importance of consistency in witness testimony and the need for the prosecution to build a watertight case, especially when the stakes are as high as life and liberty.
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