|Citation||1992 SCR (2) 605|
|Date of Judgment||21.04.1992|
|Court||Supreme Court of India|
|Case Type||Criminal Appeal No 572 of 1981|
|Appellant||MUNNI SINGH & ORS|
|Respondent||The State of BIHAR|
|Bench||PUNCHHI, M.M. AGRAWAL, S.C. (J)|
|Referred||Section 396 I.P.C., Evidence Act|
FACTS OF THE CASE
Munni Singh and others were accused of dacoity with murder. The prosecution alleged that the accused had committed dacoity in the house of one P.W. 11, in which P.W. 11’s uncle was killed. P.W. 11 and his cousin P.W. 3 identified the accused as having been involved in the dacoity.
Whether the accused could be convicted of dacoity with murder on the basis of the identification evidence of P.W. 11 and P.W. 3.
The accused argued that the identification evidence of P.W. 11 and P.W. 3 was unreliable, as they had only seen the accused in torchlight. The accused also argued that they had no motive to commit the crime.
The prosecution argued that the identification evidence of P.W. 11 and P.W. 3 was reliable, as they had known the accused for many years. The prosecution also argued that the accused had a motive to commit the crime, as they had a dispute with P.W. 11’s family.
The court allowed the appeal.
The Supreme Court acquitted the accused of all charges. The Court found that the identification evidence of P.W. 11 and P.W. 3 was not reliable, as they had only seen the accused in torchlight. The Court also found that the prosecution had failed to prove beyond a reasonable doubt that the accused had a motive to commit the crime.
The Supreme Court’s decision in Munni Singh & Ors v/s State of Bihar, 1992 is a reminder of the importance of reliable identification evidence in criminal cases. The Court noted that it is difficult to identify someone in torchlight and that the prosecution must be careful when relying on identification evidence from witnesses who saw the accused in low light conditions.
The Court also noted that it is important for the prosecution to prove motive in criminal cases. While motive is not an essential element of the crime, it can help the court to assess the credibility of the prosecution’s case.
This Article is written by Anirudh Modi of Maharishi University of Information Technology, Noida, Uttar Pradesh, an intern at Legal Vidhya.