LI Network
Published on: December 15, 2023 at 11:40 IST
The Supreme Court, acquitted an individual convicted by the Madras High Court under Section 304 (culpable homicide not amounting to murder) of the IPC.
The Court ruled that the prosecution failed to establish the accusation beyond a reasonable doubt, making the acquittal necessary in the interest of justice.
A bench comprising Justice BR Gavai, Justice Dipankar Datta, and Justice Aravind Kumar asserted that a conviction can be based on partial evidence if credible. However, in this case, the prosecution’s version was deemed wholly unreliable.
The case involved a quarrel between the appellant and the victim over wage demands. The appellant allegedly attacked the victim with a rubber stick, resulting in the victim’s death. The High Court found the appellant guilty under Section 304-Part II of the IPC, sentencing him to five years’ rigorous imprisonment.
The court concluded that while the appellant caused the head injury leading to the victim’s death, there was no intention to commit murder.
The Supreme Court, after scrutinizing the evidence, concluded that the circumstances favored the inference that the victim was under the influence of alcohol, fell from a tree, suffered a head injury, and subsequently died.
The Court highlighted the prosecution’s failure to present material witnesses, and the delay in filing the FIR was not satisfactorily explained. The Court also noted that medical documents supporting the victim’s head injury were not produced.
The judgment emphasized that delay in FIR filing, if not satisfactorily explained, could be detrimental to the prosecution’s case.
The Court further highlighted the need for a realistic and pragmatic approach, considering the peculiarities of each case. The appellant’s three-year absence was deemed a common reaction when facing imminent apprehension.
The Supreme Court, in setting aside the conviction, stated that the circumstances surrounding the victim’s death did not unequivocally implicate the appellant, and his false implication could not be ruled out.
Case Title: SEKARAN V. THE STATE OF TAMIL NADU, CRIMINAL APPEAL NO. 2294 OF 2010