Supreme Court Upholds Conviction in 1985 Jharkhand Murder Case, Apex Court Confirms Life Imprisonment for Accused, Cites Reliable Eyewitness Testimonies and Medical Evidence
In a landmark decision, the Supreme Court of India has upheld the conviction of Ghanshyam Mandal and others, who were sentenced to life imprisonment for the murder of Bulaki Mandal and Hriday Mandal in 1985. The judgment, delivered by Justices J.K. Maheshwari and Atul S. Chandurkar, reaffirms the verdicts of the Jharkhand High Court and the Sessions Court, rejecting the appeals filed by the accused.
The case stems from an incident that occurred on August 15, 1985, when the accused allegedly assaulted and killed the victims over a dispute involving grazing goats. Despite the absence of recovered weapons, the Supreme Court found the prosecution's case robust, relying heavily on consistent and reliable eyewitness testimonies and medical evidence.
The appellants challenged their conviction on several grounds, including the reliance on testimonies from related witnesses, the lack of weapon recovery, and alleged procedural inadequacies during their examination under Section 313 of the Criminal Procedure Code. The defense argued that the witnesses were biased due to their relationship with the victims, and questioned the validity of the prosecution's evidence.
However, the Supreme Court dismissed these contentions, emphasizing that the consistency of the eyewitness accounts and the corroborative medical evidence were sufficient to uphold the conviction. The court cited previous rulings, underscoring that the non-recovery of weapons does not necessarily weaken a prosecution case if other evidence is compelling.
The judgment also addressed the issue of the appellants' examination under Section 313, concluding that while there were general questions posed, no prejudice was demonstrated that would undermine the fairness of the trial.
Ultimately, the Supreme Court found no reason to overturn the lower courts' findings, thereby affirming the life sentences of the accused. This judgment reinforces the principle that robust and consistent eyewitness testimony, supported by medical evidence, can sustain a conviction even in the absence of physical evidence such as weapons.
Bottom Line:
Absence of recovery of weapons of assault does not weaken the case of the prosecution if there is reliable ocular and medical evidence corroborating the occurrence.
Statutory provision(s): Indian Penal Code, 1860, Section 302, Section 34; Criminal Procedure Code, 1973, Section 313
Ghanshyam Mandal v. State of Bihar (Now Jharkhand), (SC) : Law Finder Doc id # 2858565
