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        <h1>Supreme Court Affirms Convictions & Sentences in Criminal Case</h1> <h3>Ezhil & Ors. Versus State Of Tamil Nadu</h3> Ezhil & Ors. Versus State Of Tamil Nadu - 2002 AIR 2017, 2002 (3) SCR 431, 2002 (9) SCC 189, 2002 (4) JT 375, 2002 (4) SCALE 102 Issues Involved:1. Conviction under Sections 364, 392, 302 read with Section 34, IPC, and Section 120B of the Indian Penal Code.2. Sentencing, including the imposition of the death penalty.3. Evaluation of evidence and the application of legal presumptions under Sections 106 and 114 of the Indian Evidence Act.Issue-wise Detailed Analysis:1. Conviction under Sections 364, 392, 302 read with Section 34, IPC, and Section 120B of the Indian Penal Code:The accused were charged with offences under Sections 364, 392, 302 read with Section 34, IPC, and Section 120B of the IPC. The Trial Judge found the first accused guilty under Sections 364, 302, 392, and 201, IPC, while the second and third accused were found guilty under Sections 364, 302 read with Section 34, 392 read with Section 34, and 201, IPC. The High Court upheld the conviction under Sections 302 and 392, IPC, with modifications, but acquitted the accused under Sections 364 and 201, IPC. The High Court also modified the death sentence of the first accused to life imprisonment.2. Sentencing, including the imposition of the death penalty:The Trial Judge imposed the death sentence on the first accused for the offence under Section 302, IPC, and rigorous imprisonment for ten years under Section 364, IPC, for all accused. Life imprisonment was awarded to the second and third accused under Section 302 read with Section 34, IPC. The High Court modified the death sentence of the first accused to life imprisonment and affirmed the life imprisonment for the second and third accused under Section 302 read with Section 34, IPC. The sentences for the offence under Section 392, IPC, were upheld.3. Evaluation of evidence and the application of legal presumptions under Sections 106 and 114 of the Indian Evidence Act:The case was based on circumstantial evidence, with significant reliance on the recovery of articles belonging to the deceased from the car in the possession of the accused. The prosecution established the presence of the accused in the car with the deceased's belongings, including blood-stained articles. The courts applied the presumptions under Sections 106 and 114 of the Indian Evidence Act, noting that the accused failed to provide a reasonable explanation for their possession of the deceased's articles. The courts found the prosecution's evidence sufficient to substantiate the charges beyond a reasonable doubt.Detailed Analysis:The evidence included the interception of the car by PW-4, the discovery of the deceased's belongings, and the blood-stained articles in the car. The prosecution relied on the testimony of witnesses, including PW-15 and PW-23, who identified the articles sent with the deceased. The courts noted the proximity of the accused's possession of the deceased's articles to the time of the murder, supporting the presumption of their involvement in the robbery and murder.The courts also considered the legal principles governing the application of Sections 106 and 114 of the Evidence Act. The Supreme Court referenced the decision in Sanjay Alias Kaka vs. State (NCT of Delhi), emphasizing the importance of the 'important time factor' in drawing presumptions. The courts found that the accused's failure to explain their possession of the deceased's articles justified the presumption of their guilt.The Supreme Court affirmed the findings of the Trial Court and the High Court, concluding that the evidence supported the conviction under Sections 302 and 392 read with Section 34, IPC. The Court also upheld the sentences, noting that the gravity of the offences warranted rigorous imprisonment for life and ten years for robbery.In conclusion, the Supreme Court dismissed the appeals, affirming the convictions and sentences imposed by the lower courts. The Court emphasized the importance of a rational and realistic approach in evaluating circumstantial evidence and the application of legal presumptions to ensure justice in criminal trials.

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