Supreme Court Discharges Appellant from Bail Bonds, Emphasizes Trial Court's Findings

RAMESH BABULAL DOSHI Versus STATE OF GUJARAT

RAMESH BABULAL DOSHI Versus STATE OF GUJARAT - 1996 AIR 2035, 1996 (2) Suppl. SCR 265, 1996 (9) SCC 225, 1996 (6) JT 79, 1996 (4) SCALE 185 Issues Involved:
1. Whether the prosecution conclusively proved that the appellant committed the murder and removed the dead body to screen himself from legal punishment.
2. Whether the High Court was justified in reversing the acquittal by the Sessions Judge based on reappraisal of evidence.

Summary:

Issue 1: Prosecution's Proof of Murder and Removal of Dead Body
The prosecution relied on circumstantial evidence to prove the appellant's guilt. The key circumstances included:
- The appellant and the deceased were seen together on a scooter on September 2, 1980.
- The deceased was seen talking with the appellant in his flat around 1:30 PM on the same day.
- On the morning of September 3, 1980, the appellant was seen with a trunk emitting a foul smell, which later contained the deceased's body.
- Blood-stained trousers were seized from the appellant's flat.
- Diamonds worth Rs. 63,000/- were recovered from the appellant at the time of his arrest.
- Articles containing human blood of Group A, matching the deceased's blood group, were found in the appellant's flat.
- A piece of string similar to the one used to tie the deceased's body was found in the appellant's flat.

The trial court found the prosecution's evidence insufficient and unreliable, particularly questioning the credibility of witnesses who delayed their statements and the implausibility of the appellant committing the murder in his flat without being noticed by neighbors. The trial court also found the recovery of blood-stained articles on September 9, 1980, suspicious, given that the flat was locked and the keys were with the appellant's brother-in-law.

Issue 2: High Court's Reversal of Acquittal
The High Court independently reappraised the evidence and concluded that the prosecution had proved the appellant's guilt beyond reasonable doubt. However, the Supreme Court criticized this approach, stating that the High Court failed to address whether the trial court's reasons for acquittal were proper. The Supreme Court emphasized that an appellate court should only interfere with an acquittal if the trial court's findings are palpably wrong, manifestly erroneous, or demonstrably unsustainable.

The Supreme Court found the trial court's reasons for acquittal cogent and convincing, particularly regarding the credibility of witnesses and the suspicious recovery of evidence. Consequently, the Supreme Court held that the High Court was not justified in disturbing the acquittal.

Conclusion:
The appeal was allowed, and the appellant, who was on bail, was discharged from his bail bonds.