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Suresh Yadav @ Guddu vs. The State of Chhattisgarh

Criminal Appeal · 2022 INSC 233Decided 25 Feb 2022
Criminal Appeal No. 1349 of 2013
Dinesh Maheshwari · Vikram Nath

Background

The appellant was convicted of murder under Section 302 IPC (and offences under the Arms Act) for fatally stabbing a woman with whom he was allegedly having a love affair, after he saw her talking to another boy. The post-mortem found 12 injuries including penetrating wounds to the lungs and liver, and an eyewitness testified to seeing the appellant repeatedly stabbing the deceased; the knife used was also recovered based on the appellant's disclosure. Both the trial court and the High Court concurrently found him guilty and upheld a sentence including life imprisonment. He appealed to the Supreme Court through an amicus curiae, arguing there was no forensic blood-matching evidence, that the eyewitness was unreliable for not intervening or raising an alarm, and that the number of injuries suggested more than one attacker.

Decision Breakdown

The Supreme Court dismissed the appeal, reiterating settled principles that an appeal by special leave against concurrent findings of fact by the trial court and High Court is not a routine re-hearing: interference is warranted only in rare cases of manifest illegality, error of law, or serious misreading of evidence, none of which were shown here. The Court held the eyewitness's credibility was not undermined merely because he did not intervene during a sudden, ferocious attack, and that multiple injuries of similar size and nature pointed to repeated blows by the same weapon and person, not necessarily multiple attackers. The Court noted the appellant had already been released after serving over 15 years under a state remission order, and clarified that dismissing the appeal would not affect that remission.

Lesson Learnt

The Supreme Court will not re-weigh evidence or substitute its own view for concurrent factual findings of the trial court and High Court in a criminal appeal unless there is a clear legal error or serious miscarriage of justice: merely disagreeing with how eyewitness testimony was assessed is not enough to overturn a conviction at this stage.

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

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