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Lal Mohammad Manjur Ansari vs. The State of Gujarat

Not available · 2024 INSC 475Decided 8 Jul 2024
Not available
Justice Abhay S. Oka · Justice Ujjal Bhuyan

Background

The appellant and the deceased shared a rented room in Surat and had a dispute over playing music, which allegedly escalated into the appellant fatally attacking the deceased in 2004. The prosecution's case rested mainly on an alleged extra-judicial confession the appellant made to his employer (PW-19), a dying declaration the deceased supposedly made to a friend (PW-24), and several eyewitnesses who were later declared "hostile" (i.e., they did not support the prosecution's version in court). Both the trial court and the Gujarat High Court had convicted the appellant and sentenced him to life imprisonment, relying on selective parts of the hostile witnesses' testimony along with the confession and dying-declaration evidence.

Decision Breakdown

The Supreme Court found the alleged extra-judicial confession unbelievable and legally unusable. It was unnatural for the appellant to confess to an employer he had known only five months, the phone numbers involved were never investigated, and the police officer supposedly present at the second confession was never examined as a witness (and in any case a confession made to police cannot be used against an accused under Section 25 of the Evidence Act). The claimed dying declaration was equally unreliable, since the witness's own police statement was disputed and another witness present at the same time said the deceased never spoke. Scrutinizing each hostile witness's testimony individually, the Court found nothing reliable actually connecting the appellant to the murder. It therefore set aside the conviction and sentence and acquitted the appellant.

Lesson Learnt

A murder conviction cannot rest on an extra-judicial confession or a dying declaration that is contradicted by other evidence and unsupported by proper investigation (such as failing to examine a key witness). Courts must carefully test each piece of such evidence rather than accepting it at face value, especially when eyewitnesses turn hostile.

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

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