Case Note & Summary
The case involved four appellants accused of kidnapping and murdering a four-year-old child, Ranjeet Mohanty, with the prosecution alleging that the crime was committed as part of a human sacrifice ritual. The FIR was lodged by the child's uncle, PW7, who claimed to have witnessed A3 carrying the child's body. The prosecution relied heavily on the testimonies of PW7 and PW14, the latter being an employee of A1, who provided detailed accounts of the events leading to the child's murder. The Additional Sessions Judge found the appellants guilty and imposed the death penalty, a decision upheld by the High Court. However, the Supreme Court scrutinized the evidence, particularly the reliability of PW14, who had delayed reporting the incident and whose testimony lacked corroboration. The court noted that the investigation was inadequate, and critical evidence, such as the child's severed tongue, was not properly handled. Consequently, the court granted the appellants the benefit of doubt, overturning their convictions. In contrast, the court found sufficient evidence against A3, who was caught disposing of the body, and upheld his conviction under Section 302 IPC, converting his death penalty to life imprisonment. The appeals of the other three appellants were allowed, and they were ordered to be released if not required in other cases.
Headnote
A) Criminal Law - Conviction and Sentencing - Death Penalty - Rarest of Rare Case - The appellants were convicted for kidnapping and murder of a child, with the death penalty imposed by the Sessions Court and confirmed by the High Court. The Supreme Court found that the conviction was primarily based on the testimony of a witness whose credibility was questionable, leading to the conclusion that the appellants were entitled to the benefit of doubt. Held that the death penalty was not justified for the appellants (Paras 1-4). B) Criminal Law - Evidence - Extra-Judicial Confession - The third accused was convicted based on strong circumstantial evidence and an extra-judicial confession made before witnesses. The court maintained that despite the weakness of extra-judicial confessions, they could support circumstantial evidence when corroborated by other facts. Held that the conviction under Section 302 IPC was sustainable for the third accused (Paras 5-6).
Issue of Consideration
Whether the conviction of the appellants for kidnapping and murder was sustainable based on the evidence presented.
Final Decision
The Supreme Court allowed the appeals of the first, second, and fourth accused, granting them the benefit of doubt and setting aside their convictions. The conviction of the third accused was upheld, but the death penalty was converted to life imprisonment.
Law Points
- Death penalty
- human sacrifice
- extra-judicial confession
- corroboration of evidence
- circumstantial evidence
