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Criminal · Reportable judgment

Uma & Anr. vs The State Rep. by the Deputy Superintendent of Police

Court
Supreme Court of India
Date
22 October 2024
Case No.
Criminal Appeal No. 757 of 2015
Result
Dismissed
Bench
Bela M. Trivedi, Satish Chandra Sharma
Citation
[2024] 10 S.C.R. 1757 : 2024 INSC 809
Acts & Sections
CrPC IPC Evidence Act
Supreme Court Reports [2024] 10 S.C.R. 1757 : 2024 INSC 809
Issue for consideration
Whether the High Court was able to demonstrate perversity and non-appreciation of the materials on record by the Trial Court while reversing its finding of acquittal.
Headnote

Penal Code, 1860, s.120B, 302, 201; Tamil Nadu Prohibition of Harassment of Women Act, 1998, s.4A – Appellants acquitted by Trial Court – High Court in impugned judgment reversed the finding of acquittal and convicted the Appellants – Held, High Court has demonstrated perversity and non-appreciation of the materials on record by Trial Court – Appeals dismissed: Held: The Trial Court acquitted the Appellants as it concluded that the prosecution had not proven the case beyond reasonable doubt; in the absence of ocular evidence, the Trial Court did not consider it appropriate to award due to the medical evidence; and held the motive to be highly artificial and unbelievable – Findings reversed by the High Court after thorough re-appreciation of the evidence on record – Post mortem report supported the case of homicide on account of clear motive and presence of Appellants at the time the incident occurred – Appellate Court must not ordinarily reverse the finding of acquittal, unless perversity and non-appreciation of the materials on record is demonstrated – Prosecution has proved its case beyond reasonable doubt and established chain of circumstances – Conclusion of guilt can be drawn. [Para 28]

Circumstantial Evidence – Five golden principles – Panchsheel of proof – Prosecution has proved its case beyond reasonable doubt:

Held: That the prosecution has proved its case beyond reasonable doubt, established the complete chain of circumstances including the – (i) motive (ii) presence of the Appellants at the time of incident

(iii) false explanation in the statement under Section 313 of the CrPC (iv) the conduct of the Appellants before and after the incident & most pertinently (v) the medical evidence which in all human probability only correspond to the guilt of the Appellants. [Para 21] Circumstantial Evidence – When offence is committed in the privacy of a house, where accused is said to have been present – Two important consequences play out – Section

106 of Indian Evidence Act – Appellants have not discharged their burden:

Read the full headnote (2 more paragraphs)

Held: Two important consequences that play out when an offence is said to have taken place in the privacy of a house, where the accused is said to have been present – Firstly, the standard of proof expected to prove such a case based on circumstantial evidence is lesser than other cases of circumstantial evidence, and secondly, the accused would be under a duty to explain as to the circumstances that led to the death of the deceased – limited shifting of the onus of proof – If accused remains quiet or offers a false explanation, then such a response would become an additional link in the chain of circumstances – Appellants have not discharged their burden that the injuries sustained by the deceased were not homicidal and not inflicted by them. [Para 24] Reliance on medical evidence:

Observation of the Trial Court that in absence of a direct occurrence witness, motive to commit the crime and the evidence being purely circumstantial in nature, the medical evidence becomes of less consequences – Not a fairly plausible view. [Para 27]

Keywords: Reversal of Judgment of Acquittal · Circumstantial Evidence

As published in the Supreme Court Reports, Supreme Court of India. Headnotes prepared by: Prastut Mahesh Dalvi, Hony. Associate Editor (Verified by: Shibani Ghosh, Adv.). Text from the Indian Supreme Court Judgments open data set (Dattam Labs), CC BY 4.0.

Full Judgment Text

Judgment Satish Chandra Sharma, J. Introduction 1. These appeal(s) assail the correctness of the Final Judgment/Order dated 04.03.2015 passed by the Hon’ble High Court of Madras at Madurai (the “High Court”) in Criminal Appeal (MD) No. 161 of 2011 titled State Vs Uma & Ors. whereby the judgement of acquittal dated 19.10.2010 passed by the Additional Sessions Judge, Fast Track Court No.1, Thoothukudi (the “Trial Court”) in Sessions Case No.300 of 2009, has been reversed and consequently, Appellant No.1/Accused No.1 has been convicted and sentenced to undergo imprisonment for life under Secti
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