Dashrath @ Jolo & Anr. v. State of Chhattisgarh
Background
During a neighbourhood dispute that began when a man was invited to a child's "chhati" (sixth-day birth) celebration, the appellants, armed with a battleaxe and sticks, assaulted several people who tried to intervene, killing three persons (Chhedilal, Bablu and Bhuru @ Parmanand) and injuring two others. The trial court convicted the appellants of forming an unlawful assembly with the common object of murder, and the Chhattisgarh High Court upheld the conviction and sentence. The appellants challenged the conviction before the Supreme Court, arguing they acted in self-defence and that the prosecution failed to explain injuries found on their own bodies.
Decision Breakdown
The Supreme Court rejected the self-defence claim, finding that the complainant's party was unarmed while the appellants were armed with weapons, so the appellants, not the complainants, were the aggressors. On the unexplained-injuries argument, the Court reiterated that the prosecution is only obliged to explain injuries on an accused when those injuries are serious and shown to have arisen from the same incident; here the injuries were simple and medical evidence suggested they could even have been self-inflicted. Finding the conviction properly reasoned by both lower courts, the Supreme Court dismissed the appeals and upheld the conviction and sentence under Section 302 read with Section 149 IPC.
Lesson Learnt
A claim of self-defence fails where the evidence shows the accused, not the complainant, was the armed aggressor; and the prosecution need not explain every injury on an accused unless it is shown to be serious and clearly connected to the incident.