State of Rajasthan etc. v. Bablu @ Om Prakash etc.

Special Leave Petition (Criminal) · 2021 INSC 782Decided 24 Nov 2021
Special Leave Petition (Criminal) No. 8676 of 2019
Justice Uday Umesh Lalit · Justice Ajay Rastogi

Background

On the festival of Holi in 2012, a group of about 13 men from a rival faction allegedly stormed into a house in Kota, Rajasthan, armed with swords, iron rods and pipes, and beat Dhanpal and his brother Sunil, who had intervened; Dhanpal later died of his injuries. The trial court convicted all 13 accused based on the testimony of the injured witness and several eyewitnesses, but the Rajasthan High Court acquitted 11 of them on appeal, upholding conviction for only 2, reasoning that no specific weapon/injury was clearly attributed to each of the others and that the case might reflect over-implication arising from an unrelated incident four days earlier. The State and the complainant appealed the acquittals to the Supreme Court.

Decision Breakdown

The Supreme Court found the High Court's reasoning "manifestly erroneous and perverse," holding that the eyewitness accounts, especially of the injured witness Sunil and another witness Tulsiram, corroborated by others, were consistent, credible and specific enough to sustain conviction, and that the legal test from Masalti v. State of U.P. (requiring multiple witnesses per accused) applies only where accused are merely alleged to be present in an unlawful assembly, not where specific overt acts are clearly attributed to them by name. As a safeguard against over-implication, the Court applied a stricter standard than legally required, restoring conviction only for the six accused (out of the eleven acquitted) whose roles were corroborated by at least two reliable eyewitnesses, while upholding the acquittal of the remaining five on benefit of doubt. The six were ordered to surrender within four weeks or face arrest.

Lesson Learnt

An appellate court cannot overturn eyewitness-based convictions simply by demanding an unrealistically high corroboration standard; where witnesses give clear, specific and consistent evidence naming an accused and the act committed, that evidence can sustain a conviction even without a strict "minimum number of witnesses" rule.

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