1. Case Background (Para 2-3):

• The case arises from the brutal murder of two individuals from a Scheduled Caste, Mohan Ram and Bodha Devi, on the night of 21/22 April 1998. The accused (Radhey Shyam Lal, Pratap, Rajesh Kumar, and Jagannath) assaulted the victims and disposed of their bodies in a well. An FIR was lodged the next morning under sections 302/34 of the IPC and Section 3(1)(v) of the SC/ST Act.

2. Trial Court Proceedings (Para 5-7):

• The trial commenced based on the evidence of the two eyewitnesses (PW1 and PW2), the medical and forensic reports, and other police documents. Despite objections from the defense, these documents were exhibited without calling their authors, as the defense had admitted their genuineness. The trial court convicted the accused under Section 302 IPC and sentenced them to life imprisonment in July 2019.

3. High Court Judgment (Para 8):

• The Allahabad High Court allowed the appeal of the accused, ruling that the lack of formal proof of prosecution documents was a violation of fair trial principles. It ordered a retrial starting from the stage of cross-examining PW2 and called for formal proof of all documentary evidence.

4. Supreme Court Decision (Para 10-22):

• The Supreme Court found that the High Court erred in remanding the matter. Section 294 of the CrPC allows documentary evidence to be admitted without formal proof if its genuineness is not disputed. The defense had repeatedly admitted the documents. Therefore, the trial court's reliance on such evidence was valid.

Legal Provisions Discussed

• Indian Penal Code (IPC): Section 302/34 (Murder with common intention).
• Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act: Section 3(1)(v).
• Criminal Procedure Code (CrPC): Section 294 (Formal proof of documents).
• Evidence Act, 1872: Section 145 (Impeaching the credit of witnesses).

Ratio Decidendi

• The Supreme Court clarified that under Section 294 of the CrPC, once the defense admits the genuineness of prosecution documents, formal proof is not required. The High Court's remand for re-examination was unnecessary, as the trial court properly relied on the admitted documents. This upholds the doctrine that parties cannot retract admissions made during trial unless substantial injustice is shown.

Subjects:

Fair Trial, Admissibility of Evidence

Criminal Law, SC/ST Act, Murder Trial, CrPC Section 294, Documentary Evidence