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Chandra Prakash v. State of Rajasthan

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1155 of 2014)Decided 9 May 2014
Criminal Appeal No. 1155 of 2014
Justice K.S. Radhakrishnan · Justice Dipak Misra

Background

A bomb exploded at Jaipur's Sawai Man Singh Stadium before a Republic Day function in 1996, injuring a passer-by and damaging property. Investigators later recovered another live bomb and explosive-making materials. Four convicted persons challenged the evidence, prosecution consent, identification process and proof of their roles.

Decision Breakdown

The Court dismissed all the appeals and upheld the convictions and sentences. It found valid consent from the District Magistrate and no fatal defect in the identification procedure or charges. The accomplice who testified was considered credible and was corroborated by independent witnesses and recoveries. Discovery evidence could be admitted where the accused was in police custody, even if formal arrest followed the recovery. Meetings, purchases, transport of materials and other proven circumstances established the conspiracy, while the large collection of explosive-making articles supported the explosives offences.

Lesson Learnt

Conspiracy can be proved through a connected set of circumstances rather than a written agreement. An accomplice's account still requires careful scrutiny and material corroboration, while only legally admissible parts of police-custody disclosures can support the case.

Official source (sci.gov.in)View Judgment (PDF)

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