In a pivotal ruling today, the Supreme Court validated the discharge of individuals implicated in a murder case where the cause of death was contested. The decision rested on the court’s acknowledgment of the crucial role played by the expert testimony of the autopsy-performing doctor, highlighting the need to consider such professional insights in determining the culpability of the accused.
The case originated from allegations by the deceased woman’s husband, who claimed that his wife had been assaulted with sticks and kicks, resulting in her death. Conversely, the accused argued that the death was natural.
The focal point of the dispute revolved around the post-mortem report, which unequivocally stated that the death was natural, coupled with the absence of external injuries on the deceased’s body. Relying on this report, the trial court had initially discharged the accused.
However, the husband of the deceased contested this decision and sought a revision from the High Court, leading to the case being remanded back to the trial court. The accused, having been discharged, appealed against the High Court’s order.
Upon thorough examination of the evidence, the Supreme Court concluded that the High Court had erred in characterizing the trial court’s proceedings as a mini-trial. The court emphasized that the trial court had appropriately considered the case within the confines of its jurisdiction under Section 227 of the CrPC.
Significantly, the court heavily relied on the expert testimony of the doctor who conducted the post-mortem, stating unequivocally that the death was natural and finding no external injuries on the deceased’s body. This critical evidence played a pivotal role in the court’s determination of the nature of the death.
Highlighting the contradiction in the deposition made by the deceased’s husband, the court noted the absence of any injuries corresponding to the described assault in the post-mortem examination. Consequently, the court concluded that there was insufficient evidence to proceed against the accused based on the private complaint filed by the deceased’s father.
Ultimately, the Supreme Court set aside the High Court’s judgment, reinstating the trial court’s decision. The court emphasized that the High Court had overlooked the significance of the doctor’s evidence, leading to the invalidation of the impugned judgment and restoration of the original order.
In a unanimous decision, the appeals were allowed, bringing closure to the legal proceedings in the case of Ramalingam & Ors. v. N. Viswanathan.
