Arvind Kumar @ Nemichand & Ors. v. The State of Rajasthan
Background
The case arose from a violent clash between two families/groups over a disputed pathway in a Rajasthan village, in which two people died and several were injured on both sides, including the accused. Across two separate trials (the second following further investigation that added more accused), some accused were convicted of murder while others were acquitted; both the convicted accused and the complainant's side filed cross-appeals before the Supreme Court. The defence's central argument was that the investigating officers had deliberately suppressed evidence of injuries suffered by the accused themselves, undermining the prosecution's version of events.
Decision Breakdown
The Supreme Court found serious lapses in the investigation, including the unexplained non-recording of injuries sustained by two of the accused who were hospitalised around the time of the incident, contradictions about when and where the FIR was actually written, and unreliable recovery evidence. Applying the principle that an unexplained failure to account for injuries on the accused can cast serious doubt on the prosecution's version, and accepting the plea of private defence as plausible, the Court held that the convicted appellants were entitled to the benefit of the doubt. The appeals filed by the convicted accused were allowed (effectively acquitting them), while the appeals filed by the complainant's side (seeking to overturn earlier acquittals) were dismissed.
Lesson Learnt
In a criminal trial, a "defective" investigation, especially one that conceals injuries or inconvenient facts about the accused, can be fatal to the prosecution's case; the benefit of doubt must go to the accused when the investigating agency's suppression of facts throws the entire narrative into doubt.