1971 (12) TMI 127 - SC - Indian Laws

Supreme Court Convicts Accused of Murder, Highlights Circumstantial Evidence's Role in Proving Guilt Beyond Doubt.

Himachal Pradesh Administration Versus Om Prakash

The SC overturned the HC's acquittal, convicting the accused of murder under Section 302 IPC. The SC emphasized the credibility of circumstantial ... - Issues Involved:1. Motive for committing the murder.2. Deceased last seen in the company of the accused.3. Recovery of blood-stained items and dagger based on the accused's statement.4. Fingerprints of the accused found at the crime scene.Detailed Analysis:1. Motive for Committing the Murder:The High Court questioned the motive suggested by the prosecution, noting that the accused's suspension was a consequence of actions by the Bank's authorities, not solely by the deceased. The accused had no apparent grievance as the deceased had later employed him. However, the Supreme Court emphasized that the accused's request for re-employment was refused by the deceased, potentially creating ill will. The Court recognized that personal grievances, even if seemingly minor, could motivate criminal actions.2. Deceased Last Seen in the Company of the Accused:The High Court found the evidence of the accused being last seen with the deceased insufficient to incriminate him, suggesting the possibility that the accused might not have entered the building with the deceased. The Supreme Court, however, highlighted that the accused's fingerprints were found at the crime scene, and a coat button matching the accused's coat was recovered from the room, establishing his presence at the time of the murder.3. Recovery of Blood-Stained Items and Dagger:The High Court dismissed the recoveries under Section 27 of the Evidence Act due to irregularities and doubts about the independence of witnesses. It suggested that the Investigating Officer might have planted evidence. The Supreme Court disagreed, stating that the recoveries were credible and supported by witness testimonies. It noted that the accused's information led to the discovery of the items, which were stained with human blood, and the dagger was identified by a witness as purchased by the accused.4. Fingerprints of the Accused Found at the Crime Scene:The High Court rejected the fingerprint evidence, questioning the credibility of the expert's report. The Supreme Court upheld the fingerprint evidence, stating that the report from the Finger Print Bureau was admissible under Section 510 of the Criminal Procedure Code. The Court found the expert's opinion, based on more than 12 points of similarity, reliable. It also emphasized that the presence of the accused's fingerprints, along with other evidence, established his presence at the crime scene during the murder.Conclusion:The Supreme Court found the High Court's rejection of evidence unjustified, emphasizing the credibility of the circumstantial evidence. The Court concluded that the accused had a motive, was last seen with the deceased, and his fingerprints and personal items were found at the crime scene. The recoveries of blood-stained items and the dagger further implicated the accused. Consequently, the Supreme Court set aside the High Court's acquittal, convicting the accused under Section 302 of the Indian Penal Code and sentencing him to life imprisonment.