In a recent development, the Supreme Court has emphasized the need for appellate courts to extend the benefit of doubt to accused individuals when the prosecution fails to establish guilt beyond reasonable doubt, allowing for alternative interpretations distinct from lower court rulings.
A significant case, where three individuals faced a 2007 murder charge, saw the Supreme Court overturning the concurrent guilty verdicts of the trial court and High Court. Justices Abhay S Oka and Pankaj Mithal highlighted the importance of considering plausible alternative perspectives when evidence indicates a lack of definitive proof against the accused.
The court stated, “While appellate courts should exercise caution in overturning convictions, they should not hesitate to grant the benefit of doubt to the accused if the evidence suggests a plausible alternative view.”
The case involved four individuals convicted of life imprisonment under Section 302 r/w 34 IPC by the Fast Track Court, Jabalpur. Despite the High Court affirming the conviction and sentence, the Supreme Court revisited the matter during the appeals process, with one of the appellants passing away.
In the broader context, the prosecution asserted that on June 8, 2007, the victim, Pappu alias Rajendra Yadav, was fatally attacked by all four accused near Machchu Hotel. The court critically analyzed the reliance on the dying declaration of the deceased, emphasizing the need for corroboration through cogent evidence.
The court’s observations included skepticism about the dying declaration’s reliability, noting a lack of corroboration and raising questions about the witness’s credibility. In particular, the court highlighted that a relative prosecution witness, PW 13 named Rahul Yadav, could not be relied upon blindly due to his connection to the deceased.
Ultimately, the Supreme Court concluded that the testimony of PW 13 lacked credibility and the dying declaration remained uncorroborated. Consequently, the court granted the benefit of doubt to the appellant-accused, setting aside the convictions and sentences, and freeing them from custody.
This verdict underscores the Supreme Court’s commitment to ensuring a fair and rigorous examination of evidence, emphasizing the need for caution when relying on dying declarations and highlighting the significance of corroborating evidence in criminal cases.
