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Manoj Kumar v. The State of Uttarakhand

Criminal Appeal · 2019 INSC 465Decided 5 Apr 2019
Criminal Appeal No. 2122 of 2010
Justice N.V. Ramana · Justice Mohan M. Shantanagoudar · Justice Indira Banerjee

Background

The accused-appellant, a neighbour who frequently visited the complainant's household, was alleged to have entered the house while the complainant's 17-year-old daughter was home alone in 1993, attempted to force himself on her, and strangled her during the ensuing struggle before staging the death as a suicide by hanging her body. Two witnesses who came to the house around the time of the incident were turned away by the accused, who falsely told them no one was home. The trial court and the High Court convicted the accused based on circumstantial evidence, including an extra-judicial confession, and the matter reached the Supreme Court as an appeal, additionally carrying a referral question about the effect of an alleged second FIR (which both sides ultimately agreed was never actually registered).

Decision Breakdown

The Court first noted that the referred legal question about a "second FIR" did not arise on the facts since no second FIR had in fact been registered, and proceeded to decide the appeal on its merits. It found that the chain of circumstances, the accused's unexplained facial injuries, signs of struggle on the victim's body, forensic evidence that she was hanged only after losing consciousness (ruling out suicide), his absconding after the incident and failure to attend the funeral, and his eventual arrest, all corroborated the extra-judicial confession and were consistent only with his guilt. Finding no evidence of enmity that would suggest false implication, the Court held the lower courts had correctly appreciated the evidence and that the prosecution had proved its case beyond reasonable doubt. The appeal was accordingly dismissed and the conviction upheld.

Lesson Learnt

An extra-judicial confession, though treated cautiously by courts, can support a murder conviction when it is independently corroborated by multiple consistent circumstances (medical evidence, conduct of the accused, and absence of any motive to falsely implicate him): a conviction need not rest on direct eyewitness testimony alone.

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

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