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Raju Manjhi v. The State of Bihar

Criminal Appeal · 2018 INSC 669Decided 2 Aug 2018
Criminal Appeal No. 1333 of 2009
Justice N.V. Ramana · Justice S. Abdul Nazeer

Background

In the intervening night of 11th-12th January 1999, a group of 10-12 assailants, including the appellant Raju Manjhi, broke into the house of one Kamdeo Singh in a village in Gaya district, Bihar, and robbed the family of gold ornaments and cash. During the robbery, the inmates were beaten, and the father-in-law Kameshwar Singh later died of his injuries, converting the charge from simple robbery (Section 395 IPC) to dacoity with murder (Section 396 IPC). The trial court convicted the appellant and sentenced him to life imprisonment, and the Patna High Court upheld this conviction on appeal.

Decision Breakdown

The Supreme Court dismissed the appellant's appeal and upheld the conviction. The Court rejected the argument that recovery of only Rs.400 from the appellant was too flimsy a basis for conviction, holding that this recovery, combined with the appellant's confessional statement and other evidence on record, sufficiently established his participation. The Court also held that failure to conduct a test identification parade does not automatically make the evidence inadmissible, since such parades are an investigative aid, not a substantive right of the accused, and clarified that proof of motive is not essential where direct and confessional evidence already establishes guilt.

Lesson Learnt

An accused cannot escape conviction merely by pointing to the absence of a formal test identification parade or an alleged lack of "motive" evidence when there is other direct and confessional evidence linking them to the crime: courts assess the totality of the evidence, not any single missing procedural step.

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

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