Case Name: Ramu Appa Mahapatar vs. State of Maharashtra

Case Number: Criminal Appeal No. 608 of 2013

Date: February 04, 2025

Quorum: Justice Abhay S. Oka, Justice Ujjal Bhuyan

 

FACTS OF THE CASE

 

Ramu Appa Mahapatar was convicted for murder of Manda with whom he was living in a live-in relationship. Incident occurred in the chawl where they were residing. The appellant confessed to the murder before multiple witnesses including the landlord and the deceased’s relatives. The sessions Court convicted him under Section 302 IPC and similarly, 9 years later Bombay High Court confirmed the same on appeal. Appellant is now challenging before the Supreme Court of India to prove his innocence.

ISSUES

 

1. Whether the confession made by appellant before witnesses is sufficient to convict him under Section 302 IPC?
2. Whether the circumstantial evidence presented by the prosecution was strong enough to establish guilt beyond a reasonable doubt?
3. Whether material contradictions in witness statements undermined the prosecution’s case?

LEGAL PROVISIONS

 

1. Section 302, Indian Penal Code, 1861 – Punishment for murder.
2. Section 161, Criminal Procedure Code, 1973 – Statements to police and their evidentiary value.
3. Section 24, Indian Evidence Act, 1872 – Admissibility of confessions.
4. State of Rajasthan v. Raja Ram (2003) 8 SCC 180 – Principles governing extra-judicial confessions.
5. Sansar Chand v. State of Rajasthan (2010) 10 SCC 604 – Guidelines for relying on circumstantial evidence.
   

ARGUMENTS

 

Petitioner’s Arguments:

 

1. The confession was made under a confused state of mind and should not be considered valid evidence.
2. The prosecution failed to provide corroborating evidence linking the appellant to the crime.
3. There were multiple contradictions in the witness testimonies and they can be upheld in the court against the petitioner.

Respondent’s Arguments:

 

1. The confession made by the appellant was voluntary in nature and the testimony was supported by multiple witnesses, which are the deceased’s relatives.
2. According to the respondent, the appellant’s behaviour after the incident timeline also showed guilt, which helped the prosecution in strengthening their prosecution’s case.
3. Circumstantial evidence and forensic findings linked directly to the prosecution’s narrative.

ANALYSIS

 

The Supreme Court closely examined the evidentiary value of the extra-judicial confession and its admissibility. The analysis again showed that custodial confessions are weak and must be analyzed and corroborated by strong circumstantial evidence. The Court found that:

As per the arguments by the petitioner, the appellant was indeed in a confused state of mind at the time of the confession, and there is no evidence linking the appellant to the scene of

this crime. The testimonies by witnesses which seem to have placed the appellant at the scene of the crime were also filled with inconsistencies and omissions. The Court clearly stated in

its judgement that while such extra-judicial confessions can be used as evidence, they must be subjected to proper analysis and connected to evidence before presenting it to the court. After thoroughly analysing the testimonies of the witnesses, showing that their testimonies actually lacked credibility and had loopholes. The prosecution relied primarily on

circumstantial evidence, but it failed to establish any chain of events that could prove that the

appellant was guilty beyond any reasonable doubt. His actions after the incident were not of a guilty person, he himself reported the incident to many people.

 

JUDGEMENT

 

1. The appeal is allowed and the conviction of the appellant is set aside.
2. Appellant is acquitted under section 302 IPC.
3. Appellant is directed to be released forthwith unless required in any other case.
4. The Supreme Court has reiterated that extra judicial confessions must be scrutinized with care before relying upon it for conviction.
5. All other applications are dismissed.

 

CONCLUSION

 

This judgment lays down the importance of creating a proper chain of events and linking of evidence in cases where extra judicial confessions are relied upon. The Supreme Court has held that mere suspicion no matter how strong cannot replace proper evidence. By giving a fair trial and upholding the principle of ‘beyond reasonable doubt’ the Court has again relied on the basic principles of jurisprudence. This case will act as a further precedent for careful judicial analysis of extra judicial confessions so that no conviction is based on weak or unlinked circumstantial evidence. The judgment makes it clear that forensic clarity and consistency in witness testimony is necessary to uphold the sanctity of the criminal justice system.

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WRITTEN BY TANMAYEE VELLORE RAGHUNANDAN