CASE ANALYSIS – STATE OF M.P. VS. RAMJAN KHAN 2024 SCC OnLine SC 3070

INTRODUCTION

The question of law on whether oral dying declarations could be taken as evidence and the credibility of eyewitness testimony in criminal trials was examined in the case of State of Madhya Pradesh v. Ramjan Khan & Ors. (2024 SCC OnLine SC 3070). The case which arose from a murder highlights the judiciary’s cautious approach in evaluating delayed disclosures, inconsistencies in witness accounts, and the procedural importance of recording crucial evidence at the earliest opportunity. The judgement of the Supreme Court reinforces the principle that convictions in criminal law must be grounded on evidence that establishes guilt beyond reasonable doubt and that appellate interference is unwarranted where the High Court’s view is reasonable and legally sustainable.

FACTS OF THE CASE

1. This case stems from a murder that occurred on October 1, 1996 in the village of Karaikheda, Madhya Pradesh. The deceased, Naseem Khan, was allegedly attacked with deadly weapons — a sickle, axe, and stick — by three accused: Ramjan Khan, Shakir Khan, and Kadir Khan. The incident took place near a well where the deceased was said to be washing up before going home.

2. The prosecution claimed that PW-5 (the deceased’s mother) and PW-9 (his brother) witnessed the attack. According to their testimony, the accused emerged from a field and assaulted Naseem Khan. PW-5 also claimed the deceased made an oral dying declaration, identifying the accused by name.

3. The First Information Report (FIR) was lodged promptly after the incident. Medical evidence showed multiple fatal injuries consistent with the weapons alleged.

4. However, the trial court convicted the accused based on the testimonies and sentenced them to life imprisonment under Section 302 read with Section 34 of the IPC.

5. On appeal, the Madhya Pradesh High Court reversed the conviction and acquitted all three accused, citing serious inconsistencies in the eyewitness testimonies and the absence of the dying declaration in both the FIR and initial police statements under Section 161 CrPC.

6. The State then appealed to the Supreme Court, challenging the High Court’s acquittal.

ISSUES OF THE CASE

1. Whether or not the oral dying declaration allegedly made by the deceased to his mother (PW-5) could be relied upon in the absence of mention in the FIR or Section 161 CrPC statements?

2. Whether or not the testimonies of the alleged eyewitnesses (PW-5 and PW-9) were credible enough to sustain the conviction?

3. Whether or not the High Court was justified in reversing the conviction based on the inconsistencies and omissions in prosecution evidence?

JUDGEMENT

The Hon’ble Supreme Court, after thorough analysis of the record, evaluation of oral and documentary evidence, and examination of precedents, delivered its judgment dismissing the appeal filed by the State of Madhya Pradesh. In doing so, the Court upheld the acquittal of the accused persons as rendered by the Madhya Pradesh High Court. The key observations and conclusions drawn by the Court are summarised below:

1. On the Validity and Reliability of the Oral Dying Declaration

The Court began by addressing the central claim of the prosecution — that the deceased made an oral dying declaration to his mother (PW-5), naming the assailants. The Court held that while dying declarations are admissible under law, their credibility must be closely scrutinised, especially when they are oral, unrecorded, and made to interested witnesses such as relatives. It observed that in the present case, there was no reference to the dying declaration in the FIR or in the police statement under Section 161 CrPC, a material omission that went to the heart of the prosecution’s case. The Court concluded that in absence of corroboration, such belated disclosure lacked evidentiary weight and could not be relied upon to sustain a conviction.

2. On Omissions and Inconsistencies in Prosecution Evidence

The Court next evaluated the testimonies of PW-5 and PW-9, both related to the deceased and allegedly eyewitnesses to the crime. It noted material contradictions between their in-court depositions and earlier statements to police. For instance, the sequence of events, the nature of weapons used, and their position at the crime scene varied significantly. The Court reiterated the principle that minor discrepancies do not discredit a witness, but major contradictions, especially those that affect the substance of the prosecution’s case, are fatal. It held that such inconsistencies seriously impaired the credibility of the witnesses and rendered their accounts untrustworthy.

3. On the Role of the FIR in Evaluating Prosecution Story

The Court clarified that while the FIR is not expected to be an encyclopaedia of the incident, it must record essential facts promptly. The non-mention of the dying declaration and key factual elements in the FIR were considered significant omissions that undermined the narrative constructed during trial. The Court observed that the first version of events carries special evidentiary value and should align with later testimonies unless satisfactorily explained.

4. On Appellate Review of Acquittals

The Court reaffirmed that in criminal appeals against acquittal, the scope of interference is limited. An appellate court is not to re-evaluate evidence merely because another interpretation is possible. If the High Court’s view is plausible and based on sound reasoning, the Supreme Court should not disturb it. In this case, the High Court had carefully assessed the evidence and found that the benefit of doubt ought to be given to the accused. The Supreme Court, agreeing with this view, declined to interfere.

5. On the Standard of Proof in Criminal Trials

The judgment underscored that the burden lies heavily on the prosecution to prove guilt beyond reasonable doubt. Where evidence is inconclusive, witnesses are unreliable, and material facts are omitted, courts must not risk convicting potentially innocent persons. The Court observed that errors in investigation or exaggeration in witness testimony cannot be used to fill gaps in prosecution’s case.

6. Policy Rationale

The Bench observed that the long delay in the trial — nearly 28 years — necessitated heightened caution. Witness memories fade, and procedural lapses can multiply over time. The Court acknowledged that while delay does not by itself warrant acquittal, it amplifies the need for solid, consistent, and timely evidence.

7. Final Disposition

For all the aforementioned reasons, the Hon’ble Supreme Court concluded that the High Court’s decision to acquit was both legal and just. It held that the accused were entitled to the presumption of innocence, which had not been rebutted. The appeal was dismissed, and the acquittal affirmed.

REASONING

The Supreme Court’s reasoning in this case was rooted in the principles of criminal jurisprudence, particularly regarding the standard of proof, credibility of witnesses, and the evidentiary value of dying declarations.

1. Unreliability of the Oral Dying Declaration

A central issue in the prosecution’s case was the alleged oral dying declaration made by the deceased to his mother (PW-5), wherein he purportedly named the accused as his attackers. However, the Court observed that this declaration was not mentioned in the First Information Report (FIR) nor in the Section 161 CrPC statements given to the police by PW-5. This omission was considered fatal to the prosecution’s case.

The Court stressed that while dying declarations, even when oral and made to relatives, are admissible in evidence, they must be subjected to careful scrutiny, especially when not recorded by a magistrate or disinterested party. The delay in disclosure of such a critical piece of evidence raised serious doubts about its truthfulness. The Court also questioned whether the deceased was in a physical and mental state to make a coherent statement, given the severity of his injuries.

Consequently, the dying declaration was held to be unsafe to rely on in the absence of corroboration or timely documentation.

2. Material Contradictions in Eyewitness Testimonies

The prosecution relied heavily on the testimonies of PW-5 (the deceased’s mother) and PW-9 (his brother), both of whom claimed to have witnessed the murder. However, the Supreme Court found material inconsistencies in their accounts:

Their presence at the scene was not convincingly established.

Their statements in court differed from their earlier statements to the police.

Their sequence of events was contradictory and lacked clarity.

The Court held that in a case where conviction is based primarily on eyewitness accounts, such inconsistencies and contradictions become significant. The Court applied the principle that when witness statements are inconsistent with material facts, they become unreliable, and the benefit of doubt must go to the accused.

3. Failure to Prove Guilt Beyond Reasonable Doubt

The Court reiterated the foundational principle of criminal law — that an accused is presumed innocent until proven guilty beyond reasonable doubt. In this case, the inconsistencies in testimony, the suspicious delay in revealing the dying declaration, and the failure to properly document the same, meant that reasonable doubt persisted about the guilt of the accused.

The Supreme Court emphasized that a conviction cannot rest on conjecture or suspicion, no matter how strong. The prosecution bears the burden to eliminate doubt, and in failing to do so, their case collapses.

4. Appellate Deference to High Court’s View

The Supreme Court also noted that the High Court’s appreciation of evidence was neither perverse nor arbitrary. The High Court’s reasons for acquitting the accused — including the unreliability of witnesses and the late disclosure of the dying declaration — were based on a reasonable interpretation of the facts and evidence.

According to established legal precedent, when two views are possible, and the High Court adopts one that is reasonably supported by the record, the Supreme Court will not interfere. The apex court held that the High Court had applied the correct legal standards and its judgment did not warrant reversal.

CONCLUSION

The decision in State of M.P. v. Ramjan Khan reaffirms the judiciary’s commitment to ensuring that criminal convictions are not based on conjecture or unreliable evidence. The Supreme Court’s refusal to overturn the High Court’s acquittal underscores the importance of consistency in witness testimonies, timely disclosure of key evidence like dying declarations, and the fundamental principle of benefit of the doubt in criminal jurisprudence. This case serves as a reminder that while the pursuit of justice is paramount, it must be tempered with procedural fairness and adherence to evidentiary standards to prevent miscarriage of justice.

REFERENCES

1. State of M.P. v. Ramjan Khan, 2024 SCC OnLine SC 3070

2. Supreme Court Blog, SC upholds acquittal of three in 28-year-old murder case (2024)

3. Pahuja Law Academy Case Digest, State of M.P. v. Ramjan Khan – Criminal Appeal Analysis (2024)

Written by AJISAFE, Rachael Aduragbemi, an intern at Legal Vidya

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