Summary
The Supreme Court upheld the High Court’s reversal of acquittal and conviction for murder and wrongful restraint under the Ranbir Penal Code. The deceased’s father was a reliable natural eyewitness whose account was supported by the prompt report, other evidence, weapon recovery and medical findings. Relationship, minor discrepancies and the absence of exhaustive detail in the FIR did not undermine the case. The trial court’s erroneous appreciation justified appellate intervention; the accused’s appeal was dismissed.
Issues
- Whether the related eyewitness, prompt reports and corroborating evidence proved the assault beyond reasonable doubt.
- Whether the High Court was justified in reversing the acquittal.
Held
- The FIR need not contain every detail of the offence. The injured informant’s condition explained omissions, and the prompt oral report and later hospital statement were supported by evidence rather than grounds for rejecting the prosecution. (¶¶ 14, 15)
- Motive is of greater importance in circumstantial cases and loses significance where direct, reliable evidence proves the offence. Disputes about the precise financial arrangement did not displace the proved assault. (¶¶ 16, 17, 22, 23)
- A close relative’s testimony cannot be rejected merely for that relationship. It requires careful evaluation; the father’s presence was natural and his account was intrinsically reliable and corroborated by the surrounding evidence and medical findings. (¶¶ 18, 19, 24, 25, 26, 27, 28, 29)
- Minor contradictions not touching the root of the case do not justify wholesale rejection of otherwise credible evidence. The trial court’s hypertechnical approach caused a miscarriage of justice here. (¶ 30)
- An acquittal strengthens the presumption of innocence, and the possibility of two views alone does not justify interference. Here the trial court’s erroneous considerations and manifest irregularity in appreciating the evidence justified the High Court’s reversal on proof beyond reasonable doubt. (¶¶ 31, 32, 33)
Result
Accused’s appeal dismissed. High Court conviction under Sections 302 and 341 of the Ranbir Penal Code, life imprisonment and fines sustained.