Chandrasekar & Anr. v. State
Background
The appellants were convicted and sentenced to life imprisonment for murdering one Gnanasekaran, who was attacked with a hammer, sickle, and iron rod on the morning after he had been acquitted in an earlier criminal case brought by a co-accused, Govindaraj. A witness, the deceased's brother-in-law, was also assaulted and injured in the same incident. The trial court convicted the appellants relying on eyewitness testimony, including from the deceased's wife and an independent witness, along with medical evidence of extensive head injuries. The appellants challenged the conviction before the Supreme Court, arguing inconsistencies among witnesses and absence of proven motive for one of them.
Decision Breakdown
The Supreme Court upheld the conviction, holding that relation to the deceased by marriage does not by itself discredit a witness, though it calls for closer scrutiny of the evidence, and here the deceased's wife and other witnesses gave consistent, credible ocular testimony corroborated by extensive medical evidence of multiple head injuries. The Court found that minor inconsistencies about who arrived first at the scene did not undermine the core eyewitness account, and that with reliable direct evidence of the assault, questions about motive became largely irrelevant. It held that the deliberate, repeated blows to the head of the victim by multiple assailants, each carrying a weapon, demonstrated a shared intention to kill, making it unnecessary to separately examine "common intention" under Section 34 IPC. The appeals were dismissed, the convictions affirmed, and the appellants' bail bonds cancelled with a direction to surrender to serve out the remaining sentence.
Lesson Learnt
A witness's family relationship to a victim does not automatically make their testimony unreliable: courts scrutinise such evidence more carefully, but credible, corroborated eyewitness accounts can sustain a murder conviction even without conclusively proven motive.