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Manik & Ors. vs. The State of Maharashtra

Not available · 2024 INSC 734Decided 25 Sept 2024
Not available
Justice C.T. Ravikumar

Background

The appellants were police personnel/associates convicted by a Sessions Court in Gondia (Maharashtra) for offences including causing the death of a man named Shama @ Kaliya while he was in police custody, along with wrongful confinement, causing hurt, and destroying evidence. The Bombay High Court (Nagpur Bench) had largely confirmed these convictions. The accused appealed to the Supreme Court, and the case turned on whether the prosecution had proved, without recovery of a conclusively identified body, that Shama had actually died in custody due to torture, or whether he might have escaped as the defence claimed.

Decision Breakdown

Justice C.T. Ravikumar, writing the lead opinion, found the prosecution's story of Shama's "escape" unconvincing, particularly given uncontroverted evidence of custodial torture, but held there was insufficient specific medical/direct evidence to sustain the murder-related conviction (Section 304 Part II) and gave the accused the benefit of the doubt on that and several connected charges, while confirming their conviction for custodial torture and wrongful confinement (Sections 330, 348, and 387 IPC). Justice Sanjay Kumar disagreed, holding that the accused had fabricated an elaborate cover story (including impersonating the victim and staging a fake conviction record) precisely to escape justice, and that on the facts a homicidal death in custody could be inferred without a recovered body; he would have upheld the full original conviction and dismissed all the appeals. Because the two judges could not agree, the judgment does not record a single unified final order, and the point of difference would ordinarily need to be resolved by a larger bench.

Lesson Learnt

Indian law does not require a dead body to be recovered and identified to prove a custodial death, circumstantial evidence of torture and the accused's own fabricated cover-up can be enough, but reasonable disagreement among judges on how far that evidence goes shows how fact-heavy and difficult custodial-death cases are, and how the "benefit of the doubt" principle can produce genuinely split judicial outcomes even on serious charges.

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

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