Supreme Court Emphasizes Criticality of Timely FIRs, Acquits Accused in Landmark Judgment

In a groundbreaking decision, the Supreme Court has acquitted an individual convicted by the Madras High Court under Section 304 of the IPC, asserting that the prosecution failed to establish the accusations beyond a reasonable doubt. The Court, comprising Justices BR Gavai, Dipankar Datta, and Aravind Kumar, emphasized the importance of credible evidence and highlighted the potential fatal consequences of unexplained delays in filing FIRs.

The case centered around a dispute over wages, resulting in the victim’s death allegedly caused by the accused wielding a rubber stick. The High Court, while acknowledging the absence of premeditation, found the accused guilty under Section 304-Part II and sentenced him to five years’ rigorous imprisonment.

Upon careful examination, the Supreme Court diverged from the lower court’s decision, pointing out that the circumstances leaned towards the victim falling from a tree while under the influence of alcohol. The Court noted that the injuries were initially not deemed serious, and the accused might have been framed as the situation worsened.

Of particular significance was the Court’s scrutiny of the prosecution’s failure to examine key witnesses present during the incident. Justices Gavai, Datta, and Kumar raised questions about the absence of testimonies from Ponnaian and Velukutti, who were at the scene. The Court invoked Section 114 of the Evidence Act, highlighting the prosecution’s obligation to explain why these witnesses were not presented.

Furthermore, the Court critically assessed the delay in filing the FIR, emphasizing that unexplained delays could be detrimental to the prosecution’s credibility. While recognizing that delays alone should not undermine a case, the Court insisted on a pragmatic evaluation, considering the peculiarities of each situation.

Examining the medical evidence, the Court noted the absence of relevant documents corroborating the prosecution’s claim that the head injury resulted from the accused’s attack. The Court also dismissed the significance of the accused’s abscondence, emphasizing that it alone does not establish guilt.

Ultimately, the Supreme Court, in the case of Sekaran v. The State of Tamil Nadu (Criminal Appeal No. 2294 of 2010), set aside the conviction, stressing the need for a thorough and just evaluation of evidence, timely filing of FIRs, and the importance of addressing gaps in the prosecution’s case.