Case Title: Chandan v. The State (Delhi Admn)
Case No.: Criminal Appeal No.788 OF 2012
Dated: April, 2024
Quorum: Justice Sudhanshu Dhulia and Justice Prasanna B Varale
FACTS OF THE CASE:
In this case, the appellant (Chandan) was accused of murder. The case was first tried in the High Court of Delhi. Aggrieved by the decision, the case was then appealed to the Supreme Court. It was on May 28, 1993, the deceased (Rakesh) and the accused (Chandan) were walking a few steps ahead of the sister-in-law of the deceased.
The eyewitness (PW-2) saw the two grappling with each other, and then she witnessed the accused stabbing the deceased multiple times with a knife. Thereafter, he was taken to a nearby clinic and then to Hindu Rao Hospital, where he was declared dead. The post-mortem revealed several ante-mortem injuries, including stab wounds on different parts of the body.
CONTENTIONS OF THE APPELLANT:
Throughout the court case, the appellant made a number of arguments. He continued by claiming that the prosecution had not shown that the accused had any motivation for committing the claimed offence.
This argument is valid, but it’s important to remember that the case mostly depends on eyewitness testimony, which is reliable and rarely influenced by a lack of clear motivation. He added that the defence stressed that there is nothing to undermine the witness’s testimony because this is a daytime murder that was observed by a trustworthy eyewitness (PW-2). Consequently, given the direct sight of the action, the motive itself loses much of its significance.
CONTENTIONS OF THE RESPONDENT:
The prosecution, according to the respondent, made a point of highlighting the ocular testimony of the trustworthy eyewitness (PW-2) as strong evidence. It is less important to prove a particular purpose when an eyewitness testimony gives the court confidence.
The eyewitness testimony’s credibility is not greatly impacted by the simple lack of a clear motivation. The prosecution emphasised the type and extent of the deceased’s antemortem injuries. The medical examination revealed many wounds on different parts of the body, consistent with a vicious stabbing attack. Particularly, Injury No. 5 involved the pericardium and the tip of the left ventricle of the heart, penetrating the chest cavity and pointing upward. These wounds were enough to cause death in the ordinary course of nature.
LEGAL PROVISIONS:
- Section 302 of the Indian Penal Code: The appellant was convicted under this section, which deals with the offense of murder. It prescribes punishment for intentionally causing the death of another person.
COURT’S ANALYSIS AND JUDGMENT:
The case was first tried in the Delhi High Court. The court upheld the conviction of the appellant (Chandan) under Section 302 of the Indian Penal Code (IPC). The prosecution’s evidence, which included the accused’s arrest and an Indica automobile with bloodstains from the deceased on the rear seat, was deemed convincing by the trial court.
The Supreme Court held that the prosecution provided all the evidence necessary to prove the accused’s guilt beyond a reasonable doubt. The prosecution had established its case, as both the trial court and the appellate court correctly concluded. The credibility of the eyewitness testimony and the type of antemortem injuries the deceased had sustained were key components of the case.
To summarize, the accused was found guilty of murder by the courts because they considered the prosecution’s evidence to be credible. The absence of a clear motivation had no appreciable effect on the case, and the eyewitness testimony was essential in establishing guilt.
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Judgment reviewed by- Riddhi S Bhora
