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Shatrughan vs. The State of Chhattisgarh

Criminal Appeal · 2023 INSC 630Decided 20 Jul 2023
Criminal Appeal No. 437 of 2016
Vikram Nath · Ahsanuddin Amanullah

Background

The appellant, a forest department watchman, was convicted of murder and sentenced to life imprisonment for allegedly assaulting the deceased with a sharp weapon ("Tabbal") in 2008, based on the deceased's dying cry naming the appellant and on his uncle (the informant) claiming to have seen the appellant fleeing the scene. The trial court and the Chhattisgarh High Court both upheld the conviction. The appellant, who had already served nearly 15 years in custody, appealed to the Supreme Court arguing there was no eyewitness to the actual assault, no motive, and that the medical evidence contradicted the prosecution's version.

Decision Breakdown

The Supreme Court found that no witness had actually seen the appellant assault the deceased: the informant only saw him near the scene afterward, and other family witnesses admitted there was no enmity between the appellant and the deceased. The medical evidence directly undermined the prosecution's case: the doctor testified that the recovered weapon's size did not match the size of the neck injury, and that the deceased had consumed a significant quantity of alcohol, making it plausible he had tripped and fallen on a sharp object rather than being attacked. The Court also noted a plausible alternative motive for false implication: a village Sarpanch against whom the appellant had lodged a corruption complaint appeared to have influenced the key witness. Concluding the prosecution had failed to prove its case beyond reasonable doubt, the Court acquitted the appellant and ordered his immediate release.

Lesson Learnt

A murder conviction cannot rest on suspicion or a chain of hearsay when there is no direct eyewitness, no proven motive, and the forensic evidence (weapon-to-injury match, toxicology) actively contradicts the prosecution's story. Courts will set aside convictions, even after years of imprisonment, where the evidence does not meet the "beyond reasonable doubt" standard.

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

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