Case Note & Summary
The case pertains to the death of Mandeep Kumar on 21.10.2018 following an alleged attack by seven masked persons. The appellant, Sagar, was identified as one of the assailants who struck the deceased on the left temporal region with an iron pipe. The prosecution relied on the testimony of PW11 (complainant Mandeep Kumar) and PW12 (Aman), who claimed to be eyewitnesses. The trial court convicted the appellant under Sections 148, 323, 341, 302 read with 149 IPC, and the High Court upheld the conviction. The Supreme Court examined the evidence and found that the identification of the appellant was doubtful. PW11's testimony was inconsistent regarding the number of assailants and the sequence of events. The medical evidence indicated a single fatal injury, which contradicted the claim of multiple assailants attacking with different weapons. The Court held that the prosecution failed to prove the case beyond reasonable doubt. The appellant was granted the benefit of doubt and acquitted of all charges.
Headnote
A) Criminal Law - Murder - Identification of Accused - Benefit of Doubt - The appellant was convicted under Section 302 read with Section 149 IPC for causing death by striking with an iron pipe. The sole eyewitness (PW11) identified the appellant at the scene but his testimony was inconsistent regarding the number of assailants and the nature of the attack. The medical evidence showed a single fatal injury, contradicting the claim of multiple assailants. The Court held that the prosecution failed to prove guilt beyond reasonable doubt, and the appellant was entitled to acquittal. (Paras 1-37) B) Evidence Law - Sole Eyewitness Testimony - Corroboration - The testimony of a sole eyewitness must be reliable and corroborated by medical evidence. In this case, the eyewitness's statement was inconsistent and the medical evidence did not support the version of multiple assailants. The Court held that such testimony cannot form the basis of conviction. (Paras 20-30) C) Criminal Procedure - Appeal - Acquittal - The Supreme Court, in appeal, set aside the conviction and sentence, granting the benefit of doubt to the appellant, as the prosecution's case was not proved beyond reasonable doubt. (Paras 35-37)
Issue of Consideration
Whether the conviction of the appellant under Section 302 IPC read with Section 149 IPC is sustainable based on the testimony of a sole eyewitness whose identification of the accused is doubtful and where the medical evidence contradicts the ocular version.
Final Decision
The Supreme Court allowed the appeal, set aside the conviction and sentence, and acquitted the appellant of all charges, granting him the benefit of doubt.
Law Points
- Benefit of doubt
- Unreliable identification
- Inconsistent testimony
- Medical evidence contradiction
- Acquittal in murder case
