Case Note & Summary
The appellant, Ranjana Suresh Jadhav, was convicted by the trial court under Section 302 of the Indian Penal Code, 1860 for the murder of her co-wife, Sindhubai, by assaulting her with a stone roller. The prosecution case relied heavily on the testimony of Prakash (PW1), the stepson of both women, who claimed to have witnessed the assault. According to the prosecution, on 23rd November 1999, the deceased and the appellant were locked inside the house by their husband Suresh (PW3), who handed the key to Prakash. Prakash went to the bus station, returned home at around 1:45 p.m., heard quarrels, unlocked the door, and saw the appellant assaulting the deceased with a stone roller. The appellant then left, and Prakash lodged an FIR. The appellant was arrested and charged. The trial court convicted her, leading to this appeal. The appellant argued that the evidence was inconsistent and unreliable, particularly Prakash's testimony, which contradicted other witnesses and his own prior statements. The High Court analyzed the evidence and found that Prakash's testimony was not credible. He claimed to have returned home at 1:45 p.m., but other witnesses stated that the incident occurred earlier. Additionally, Prakash's statement that he went to the bus station and whiled away time was not corroborated. The court noted that the prosecution failed to explain why Prakash did not intervene or call for help. The medical evidence did not conclusively link the stone roller to the injuries. The court held that the prosecution had not proved its case beyond reasonable doubt, and the appellant was entitled to the benefit of doubt. The appeal was allowed, the conviction was set aside, and the appellant was acquitted.
Headnote
A) Criminal Law - Murder - Section 302 Indian Penal Code, 1860 - Conviction based on sole eyewitness - The appellant was convicted for murder of her co-wife by assaulting her with a stone roller. The sole eyewitness, the stepson, gave inconsistent testimony regarding the time of incident and his own actions. The court held that the prosecution failed to prove the case beyond reasonable doubt, and the appellant was entitled to benefit of doubt. (Paras 1-10) B) Evidence Law - Credibility of Witness - Inconsistencies in Testimony - The eyewitness claimed to have heard quarrels and seen the assault, but his testimony was contradicted by other prosecution witnesses and his own prior statements. The court held that such inconsistencies create reasonable doubt, and the conviction cannot be sustained. (Paras 5-9)
Issue of Consideration
Whether the conviction of the appellant under Section 302 of the Indian Penal Code, 1860 for murder is sustainable based on the evidence of a sole eyewitness whose testimony is inconsistent and unreliable.
Final Decision
Appeal allowed. Conviction and sentence set aside. Appellant acquitted. Fine, if paid, to be refunded.
Law Points
- Benefit of doubt
- Inconsistent testimony
- Circumstantial evidence
- Last seen theory
- Homicide by stone roller
- Section 302 IPC
