In a landmark verdict delivered on Wednesday (January 24), the Supreme Court has ruled against the admissibility of the sole recovery of a blood-stained weapon as grounds for conviction unless directly linked to the murder of the deceased by the accused.
The benc’ comprising Justices B.R. Gavai and Sandeep Mehta unequivocally held that suspicion alone cannot serve as a basis for conviction, emphasizing the cardinal principle that an accused is presumed innocent until proven guilty beyond a reasonable doubt. The judgment sets aside the concurring findings of the High Court and the Trial Court, underscoring the imperative for corroborated evidence to establish guilt.
The case in question pertained to an alleged murder committed in 2009, where the accused was accused of fatally assaulting the deceased with a dagger. While certain recoveries, including a blood-stained dagger, were made at the instance of the accused, the prosecution failed to conclusively prove that the blood stains on the weapon belonged to the deceased.
The Trial Court, despite the absence of concrete evidence, convicted the accused based on suspicious recoveries and the similarity between the recovered blanket pieces and those found near the crime scene. However, the Supreme Court deemed such circumstantial evidence insufficient to meet the burden of proof beyond a reasonable doubt.
Crucially, the court highlighted the inadequacy of the Forensic Science Laboratory (FSL) report, which failed to establish a direct correlation between the blood on the dagger and that of the deceased. Furthermore, the open accessibility of the recovery site undermined its probative value, leading the court to discredit the prosecution’s case.
Section 302 of the Indian Penal Code (IPC) pertains to the offence of murder. It states that whoever commits murder shall be punished with death or imprisonment for life, and shall also be liable to pay a fine. Murder, under this section, is defined as the intentional causing of death of another person. The section also outlines certain exceptions and situations where culpability for murder may be reduced to culpable homicide not amounting to murder, such as cases of grave and sudden provocation.
Section 313 of the Code of Criminal Procedure (CrPC) deals with the examination of the accused. This section empowers the court to examine the accused personally during the trial. The purpose of this examination is to give the accused an opportunity to explain any circumstances appearing in the evidence against them. The examination usually takes place after the prosecution has presented its case, and it allows the accused to respond to the allegations and present their defense. The accused is entitled to remain silent during this examination, and any statement made by them cannot be used as evidence against them unless they choose to offer themselves as a witness.
The judgment underscores the principle that mere suspicion cannot supplant the requirement for substantive evidence, reaffirming the presumption of innocence enshrined in law. Moreover, the court dismissed the notion that the accused’s failure to provide an explanation under Section 313 of the Criminal Procedure Code (Cr.P.C.) could serve as an additional basis for conviction, emphasizing that such non-explanation cannot substitute for the prosecution’s failure to prove guilt beyond a reasonable doubt.
In light of these considerations, the Supreme Court allowed the appeal, quashing the impugned judgment and order passed by the High Court. The verdict, encapsulated in the case titled *Raja Naykar versus State of Chhattisgarh*, marks a significant jurisprudential precedent, reaffirming the primacy of robust evidence and due process in criminal adjudication.