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Criminal LawSupreme Court of India

State of Uttar Pradesh v. Om Pal & Ors.

Criminal Appeal · 2018 INSC 252Decided 21 Mar 2018
Criminal Appeal No. 1213 of 2014
Justice N.V. Ramana · Justice S. Abdul Nazeer

Background

The accused were alleged to have shot and fatally assaulted a man on his way to his fields in 1993, following prior enmity between the families over an earlier shooting incident. The trial court convicted all three accused of murder based on the testimony of the complainant and two eyewitnesses (including the deceased's wife) and sentenced them to life imprisonment. The Allahabad High Court, on appeal, found these witnesses unreliable and acquitted all three accused. The State of Uttar Pradesh then appealed that acquittal to the Supreme Court.

Decision Breakdown

The Supreme Court examined the credibility of the three key prosecution witnesses and found serious problems with each: the complainant had not personally witnessed the incident and was admittedly hostile to the accused's family; the alleged eyewitness gave contradictory statements between his police statement and his court testimony and could not explain his presence at the scene; and the deceased's wife's claimed month-long unconscious state after the incident had no supporting medical evidence. The Court also noted a witness who claimed to have overheard a murder conspiracy the night before never warned the victim and was disbelieved even by the trial court. Agreeing with the High Court's assessment that the prosecution had failed to prove guilt beyond reasonable doubt, the Supreme Court found no illegality in the acquittal and dismissed the State's appeal.

Lesson Learnt

An appellate court will not disturb an acquittal, even in a serious case, where the prosecution's own witnesses are inconsistent, lack credible independent corroboration, or have an evident motive to implicate the accused: the burden remains on the State to prove guilt beyond reasonable doubt, not on the accused to disprove it.

State of Uttar Pradesh v. Om Pal & Ors. – Legal Case Shots | LegalAware