Court Sets Aside Conviction Due to Gaps in Circumstantial Evidence and Credibility of Witnesses
In a significant judgment, the Allahabad High Court has overturned the conviction of Om Prakash, who was sentenced to life imprisonment in a 1987 case involving the rape and murder of a young woman named Sudha. The Division Bench, comprising Justices Siddharth and Prashant Mishra-I, found that the prosecution failed to establish a complete and unbroken chain of circumstantial evidence necessary for upholding the conviction.
The case hinged on the events of February 15, 1987, when Sudha was found dead at the home of her relatives in the village of Tarbiatpur. Om Prakash and an unidentified accomplice were seen fleeing the scene, and the prosecution relied heavily on circumstantial evidence, including the presence of a book and a post-card linked to Om Prakash, found at the crime scene.
However, the High Court found several deficiencies in the prosecution's case. The court emphasized that for a conviction based solely on circumstantial evidence, the circumstances must be consistent only with the guilt of the accused and exclude any other possible hypothesis of innocence. The judgment highlighted the absence of a credible explanation for the presence of chance witnesses and discrepancies in their testimonies.
The court also noted that the nature of the injury sustained by the victim suggested the use of a weapon larger than a knife, which was allegedly wielded by the accused. Furthermore, the identity of the accomplice was never established, and the initial absence of any mention of a weapon in the FIR raised doubts about the prosecution's narrative.
Considering these factors, the High Court concluded that the evidence did not meet the stringent standards required to sustain a conviction based on circumstantial evidence. The court granted Om Prakash the benefit of doubt and set aside the trial court's decision, thereby acquitting him of all charges.
The judgment serves as a reminder of the high threshold required for convictions based on circumstantial evidence and the importance of credible witness testimony in criminal trials.
Bottom Line:
Circumstantial evidence - Conviction based solely on circumstantial evidence requires a complete chain of events that unerringly point to the guilt of the accused and exclude any other hypothesis of innocence.
Statutory provision(s): Indian Penal Code, 1860 - Sections 302, 376; Criminal Procedure Code, 1973 - Section 161; Evidence Act, 1872
Om Prakash v. State of U.P., (Allahabad)(DB) : Law Finder Doc Id # 2839611
