1979 (12) TMI 164 - SC - Indian Laws

Supreme Court Upholds Murder Conviction & Sentence Appeal Dismissal

Rajput Ruda Meha and Ors. Versus State of Gujarat

The Supreme Court dismissed the appeal by three accused individuals challenging their conviction and sentence in a murder case. The Court upheld the High ... - Issues:Appeal against conviction and sentence under the Supreme Court (Enlargement of Criminal Appellate Jurisdiction) Act, 1970; Evaluation of eyewitness testimony; Scope of power to dismiss an appeal summarily under Section 384 of the CrPC; Constitutional validity of Rule 15(1)(c) of Order XXI of the Supreme Court Rules.Analysis:The judgment pertains to an appeal by three accused individuals against their conviction and sentence in a murder case. The appellants were initially acquitted by the Sessions Judge but later convicted by the High Court based on eyewitness testimony and other evidence. The High Court found the eyewitnesses' accounts to be reliable and trustworthy, contrary to the Sessions Judge's assessment. The Supreme Court, after reviewing the evidence and the judgments of the lower courts, found no sufficient grounds to interfere and summarily dismissed the appeal under Section 384 of the CrPC.In a subsequent development, before signing the judgment, a decision of the Supreme Court in another case raised questions about the power of courts to dismiss appeals summarily under Section 384 of the CrPC. The appellants in that case challenged the constitutional validity of certain rules empowering summary dismissal of appeals. The matter was referred to a Bench of five Judges to address the constitutional validity and related issues. The Court rejected the contention that a right of appeal mandates a detailed hearing with records and reasoned judgment, emphasizing that summary dismissal is not inherently unconstitutional.The judgment clarifies that the discussion on the constitutional validity of the rules in the referred case does not extend to the validity of Section 384 of the CrPC. The Court highlighted that the specific challenge to Section 384 was not raised or argued, making the decision in that case non-binding as precedent on the validity of Section 384. The order of dismissal of the appeal summarily under Section 384 of the CrPC was upheld based on the specific circumstances and arguments presented in this case.In conclusion, the judgment addresses the appeal against conviction, the reliability of eyewitness testimony, the power to dismiss appeals summarily under Section 384 of the CrPC, and the constitutional validity of specific rules. It provides clarity on the scope and limitations of summary dismissal of appeals, emphasizing the discretion of the courts in such matters based on the facts and arguments presented in each case.