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The State of Madhya Pradesh vs. Ramjan Khan & Ors.

Not available · 2024 INSC 823Decided 25 Oct 2024
Not available
Justice C.T. Ravikumar · Justice Sudhanshu Dhulia

Background

In October 1996, Naseem Khan was allegedly beaten to death with a sickle, an axe, and a stick near a village well by three men: Ramjan Khan, Musaf Khan, and Habib Khan. The trial court, relying on eyewitness testimony from the deceased's minor brothers and mother, convicted the three accused of murder and sentenced them to life imprisonment. On appeal, the Madhya Pradesh High Court acquitted all three, finding that the eyewitnesses' testimonies contained serious contradictions and omissions compared to their earlier police statements, and disbelieving a claimed oral "dying declaration" made by the victim to his mother. The State of Madhya Pradesh appealed the acquittal to the Supreme Court.

Decision Breakdown

The Supreme Court declined to interfere and upheld the acquittal. It reiterated the settled principle that an appellate court should not overturn an acquittal just because another view of the evidence is possible: interference is warranted only where the acquitting court's reasoning is perverse or unsustainable. Reviewing the record, the Court agreed with the High Court that the mother's account of a dying declaration was never mentioned in the original police statement or FIR, and that the two eyewitness brothers had also omitted key details (like naming the weapons or the attackers) in their initial statements, only introducing them for the first time in court. Since these omissions went to the heart of the prosecution's case, the High Court's view that the benefit of doubt should go to the accused was a "reasonably possible" one, even if not the only possible one.

Lesson Learnt

Once a High Court acquits an accused after genuinely re-examining the evidence, the Supreme Court will not reverse that acquittal merely because a different view was also possible: a witness who adds crucial new details in court that were missing from their original police statement can seriously undermine the prosecution's case, even in a murder trial.

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

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