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Selvakumar vs. Manjula & Anr.

Criminal Appeal · 2022 INSC 978Decided 19 Sept 2022
Criminal Appeal Nos. 1603-1604 of 2022
A.S. Bopanna · Pamidighantam Sri Narasimha

Background

A 2006 raid on a rice mill in Tamil Nadu found several workers being held as bonded labourers. An FIR was filed against the mill's owner and his son (the appellant here, "Accused No. 2"). The owner died during trial, and the trial court acquitted the son for lack of evidence connecting him to the mill's day-to-day running. The complainant appealed, and the Madras High Court reversed the acquittal, convicting the son and sentencing him to three years' imprisonment plus compensation to the victims.

Decision Breakdown

The Supreme Court held the High Court was wrong to overturn the acquittal: none of the witnesses, including the investigating officer and the raiding revenue officer, gave any evidence that the son personally compelled anyone into bonded labour or advanced any bonded debt. Convicting him merely because the mill bore the family name and he was the owner's son was, in the Court's words, a "non sequitur," not proof beyond reasonable doubt. The Court therefore set aside the conviction and acquitted him. However, since the son had inherited his late father's business, and the statute is a social-welfare law meant to protect vulnerable workers, the Court left undisturbed the direction that he pay Rs. 50,000 compensation to each of the workmen, separate from his criminal innocence.

Lesson Learnt

A criminal conviction cannot rest on family or business association alone. The prosecution must prove the specific accused's own role beyond reasonable doubt. Separately, a person who inherits a business can still be made to pay welfare compensation to workers wronged through that business, even after being acquitted of the crime itself.

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

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