1973 (5) TMI 104 - SC - Indian Laws

Supreme Court Affirms Murder Conviction in Landmark Judgment

Lekha Yadav Versus State of Bihar

The Supreme Court upheld the High Court's judgment, affirming the appellant's conviction under Section 302, IPC, for the murder of a co-villager. The High ... - Issues Involved:1. Conviction under Section 302, IPC.2. Reversal of acquittal by the High Court.3. Evaluation of evidence by the trial court and High Court.4. Legal principles governing appeals against acquittal.Issue-wise Detailed Analysis:1. Conviction under Section 302, IPC:In this appeal, the appellant challenged his conviction under Section 302, IPC, for the murder of a co-villager. The High Court had reversed the acquittal by the trial court and sentenced the appellant to rigorous imprisonment for life. The appellant was charged under Sections 148 and 302, IPC, while the remaining accused were charged under Sections 302/149, IPC. The prosecution's case was that the appellant and other accused attacked the deceased, resulting in his death. The High Court found the appellant guilty of causing an injury sufficient to cause death in the ordinary course of nature.2. Reversal of Acquittal by the High Court:The trial court had acquitted all the accused, finding the prosecution's story incredible and unconvincing. However, on appeal by the State, the High Court re-evaluated the evidence and concluded that the appellant had indeed caused the fatal injury. The High Court found the trial court's acquittal of the appellant erroneous and convicted him under Section 302, IPC. The High Court, however, affirmed the acquittal of the other accused due to the lack of specific assault charges against them and the unsubstantiated charges under Sections 147 and 148, IPC.3. Evaluation of Evidence by the Trial Court and High Court:The trial court had dismissed the prosecution's case, doubting the credibility of the witnesses. However, the High Court, upon a detailed appraisal of the evidence, found the trial court's assessment flawed. The High Court noted that the trial court had misread part of the evidence and arrived at erroneous conclusions. For instance, the trial court's inference that the prosecution attempted to falsely implicate the accused Suresh was deemed unjustified by the High Court. The High Court found the presence of accused Suresh amongst those carrying the dead body to the police station highly unrealistic given the hostility between the groups.4. Legal Principles Governing Appeals Against Acquittal:The Supreme Court reiterated the well-settled legal position that the High Court has full power to appraise the evidence for itself in appeals against acquittal, just as it does in appeals against conviction. The High Court should bear in mind the initial presumption of innocence and the trial court's opinion, which must be dislodged before reversing the acquittal. The Supreme Court emphasized that its role under Article 136 of the Constitution is not to re-examine the entire evidence but to ensure that the High Court adhered to the guidelines laid down in precedents like Sheo Swarup's case and Sanwat Singh's case.Conclusion:The Supreme Court found the High Court's appraisal of the evidence fair and just, and concluded that the High Court had not transgressed its statutory jurisdiction. The Supreme Court upheld the High Court's judgment and order, dismissing the appeal. The High Court's conviction of the appellant under Section 302, IPC, was affirmed, while the acquittal of the other accused was also upheld.