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Stalin @ Satalin Samuvel vs State rep. by the Inspector of Police

Criminal Appeal · 2023 INSC 52Decided 18 Jan 2023
Criminal Appeal No. 636 of 2010
B.R. Gavai · Vikram Nath

Background

M.R. Ravi, a real estate businessman and local AIADMK office-bearer in Padi, Chennai, was stabbed to death in his office cabin on 2 June 2006 by a group of men, allegedly from a rival faction of the same party who believed he had got them arrested. Eighteen people were charged; the trial court convicted the accused and the Madras High Court upheld the convictions of accused Nos. 1, 2, 4, 5 and 6 while acquitting the rest. The appellants (accused Nos. 2, 4, 5 and 6) challenged their life sentences, arguing that the three eyewitnesses were not actually present and that the identification parade was unreliable.

Decision Breakdown

The Supreme Court allowed the appeals and acquitted the appellants. It found serious doubt about whether the three eyewitnesses were present at all: the Sub-Inspector's own FIR entry and the Investigating Officer's evidence suggested they arrived at the hospital after learning of the incident, their clothes were never seized, and none of them gave any description of the attackers. The TIP was held to be worthless because the police had shown the witnesses photographs and videos of the accused beforehand, the accused had been kept in the police station for eight days for the witnesses to see, the parade was conducted in an open ground, and the Magistrate never asked whether the witnesses already knew the accused. Applying Gireesan Nair v. State of Kerala, the Court held that if witnesses see the accused before the TIP, both the TIP and any later in-court identification become meaningless. The alleged recoveries were also doubtful, and the High Court's own record showed a witness had said he was tortured by police to give a statement, suggesting evidence had been manufactured.

Lesson Learnt

An identification parade proves nothing if the police have already shown the suspects to the witnesses, whether in person, by photo or by video, and a conviction cannot stand on eyewitnesses whose very presence at the scene is doubtful. The prosecution must prove its case beyond reasonable doubt; gaps and signs of fabricated evidence go to the accused's benefit.

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

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