Jharkhand High Court Holds Prosecution Failed to Prove Case Beyond a Reasonable Doubt; Acquits Accused in Murder Appeal
Criminal Appeal (D.B) No. 508 of 1998 (P)
by Rishika Sinha
The Jharkhand High Court has allowed a criminal appeal, setting aside a conviction under Section 302 IPC, holding that contradictions in prosecution evidence and reliance on an uncorroborated eyewitness cannot sustain a conviction beyond reasonable doubt. The case arose from Criminal Appeal (D.B.) No. 508 of 1998, filed by Mohanlal Tudu challenging his conviction and life sentence imposed by the learned 2nd Additional Sessions Judge, Godda, in Sessions Case No. 138 of 1997/43 of 1997.
As per the prosecution case, the informant, Marangmai Hansda, alleged that the deceased, Basta Murmu, who was working as a servant in her house, was found grievously injured during the night with his head smashed. He later succumbed to his injuries. Based on her fardbeyan, a case was registered which was subsequently converted into an offence under Section 302 IPC. During trial, the prosecution examined multiple witnesses, including an alleged eyewitness (P.W.2), on whose testimony the conviction was primarily based. The trial court, upon appreciation of evidence, held the charge proved beyond reasonable doubt and convicted the appellant.
Before the High Court, the appellant contended that the conviction was unsustainable as the prosecution case suffered from serious inconsistencies. It was argued that there were material contradictions between the testimony of witnesses and the initial version recorded in the fardbeyan, and that the case rested heavily on the testimony of a so-called eyewitness whose version was unreliable. The State, on the other hand, supported the trial court’s findings, contending that minor discrepancies ought not to discredit the prosecution case when the overall evidence points towards guilt.
The Division Bench of Justice Sujit Narayan Prasad and Justice Arun Kumar Rai examined the evidentiary record and framed key issues, including whether the material on record was sufficient to sustain conviction under Section 302 IPC and whether reliance on a single eyewitness was justified. The Court observed that while minor discrepancies do not necessarily vitiate a prosecution case, the present matter involved “serious intra-se and inter-se contradictions” in the testimonies of prosecution witnesses. It noted that the conviction was primarily based on the testimony of P.W.2, described as a self-proclaimed eyewitness, whose version lacked sufficient corroboration. Relying on settled principles laid down by the Supreme Court, including the rule that where two views are possible, the one favourable to the accused must be adopted, the Court held that the prosecution had failed to prove the charge beyond reasonable doubt.
Finding the evidence insufficient to sustain conviction, the High Court held that the trial court had erred in placing reliance on unreliable testimony without adequate corroboration. Accordingly, the High Court quashed the judgment of conviction and order of sentence, allowed the appeal, and discharged the appellant from all criminal liabilities.
