Ramvir @ Saket Singh v. State of M.P.

Citation	2024 SCC OnLine SC 542
Date of Judgement	16th April 2024
Court	Supreme Court of India
Appellant	Ramvir @ Saket Singh
Respondent	State of Madhya Pradesh
Bench	B.R. Bhargavi & Sandeep Mehta, JJ.

INTRODUCTION 

The judgement rendered on July 27, 2007, in Gwalior by the Division Bench of the Madhya Pradesh High Court is the subject of the current appeal. The ruling in Sessions Case No. 70 of 1987 by the Vth Upper Sessions Judge, Bhind, Madhya Pradesh, from November 9, 1998, was sustained by this ruling. The appellant was found guilty of killing Kaptan Singh in accordance with Section 302 of the Indian Penal Code (IPC). In addition to a life sentence and a fine of Rs. 2000, the appellant also faced two months of harsh jail for not paying the fine. Additionally, the appellant was found guilty under Section 307 IPC of attempting to kill Indal Singh (PW-12). As a consequence, he was sentenced to five years of severe imprisonment, a fine of Rs. 1000, and one month of harsh jail for not paying the fine. On November 10, 1985, two distinct incidents that resulted in the killings of Kaptan Singh and Kalyan Singh and the attempted murder of Indal Singh took place in Bhajai village, District Bhind, Madhya Pradesh. The trial court found the eyewitnesses untrustworthy and cleared the appellant of Kalyan Singh’s murder; nonetheless, they found him guilty based on the evidence of Raj Kumari, Indal Singh, and Ramraj Singh. Despite serving more than 14 years in substantive jail and almost 22 years in remission, the appellant’s release has been postponed because of the ongoing appeal. The appeal casts doubt on the veracity of the prosecution’s evidence by claiming that it made false claims and neglected to provide an explanation for the injuries sustained by appellant members who also perished in the same tragedy. The defence contends that the appellant acted in self-defence and that the complaining party was the aggressor. A connected cross-case involving members of the complainant party who were first found guilty under Section 396 IPC but were subsequently found not guilty by the High Court adds to the intricacy of the issue. After carefully examining the evidence, the appeal court rejected the appellant’s allegations of discrepancies and confirmed the existence of important eyewitnesses at the crime scene.

FACTS OF THE CASE

1. The incidents happened in Bhajai village, District Bhind, Madhya Pradesh, on November 10, 1985. The appellant was accused of killing two different people, Kaptan Singh and Kalyan Singh, as well as attempting to kill Indal Singh. 
2. On November 9, 1998, the Vth Upper Sessions Judge of Bhind, Madhya Pradesh, made a ruling. Because Hiraman and Surajbeti were untrustworthy eyewitnesses, the appellant was found not guilty of killing Kalyan Singh. Based on the testimony of Raj Kumari, Indal Singh, and Ramraj Singh, the appellant was found guilty of killing Kaptan Singh and attempting to kill Indal Singh. Then under section 302 of IPC life imprisonment and a fine of Rs 2000, with additional 2 months rigorous punishment if default in payment was awarded and under 307 of IPC five year of rigorous imprisonment and a fine of Rs. 1000, with an additional one-month rigorous imprisonment if default in payment. 
3. The appellant’s conviction for the murder of Kaptan Singh and the attempted murder of Indal Singh was upheld by the High Court on July 27, 2007, rejecting the appellant’s arguments. Despite having served over 22 years in remission and more than 14 years in substantive jail, the appellant was not allowed to be released early because of the ongoing appeal.

ISSUES RAISED  

1. Whether the testimonies of Raj Kumari’s and Indal Singh’s are trustworthy and genuine?
2. Whether the prosecution provided a sufficient justification for the appellant’s side’s deadly injuries to Chutallu @ Ram Mohan and Shiv Singh?
3. Whether the existence of the cross case, where members of the complainant party were initially convicted under Section 396 IPC, affects the credibility of the prosecution’s case and establishes that the complainant party were the aggressors?
4. Whether the appellant acted in self-defence, given the circumstances of the incident and the actions of the complainant party?

CONTENTION OF APPELLANT 

1. Shri P.H. Parekh, the appellant’s senior attorney, said that the prosecution’s whole case was made up and fraudulent. He made note of the fact that two members of the appellant’s side, Chutallu @ Ram Mohan and Shiv Singh, also suffered fatal gunshot wounds and perished in the same occurrence that claimed the life of Kaptan Singh and wounded Indal Singh. The testimony of the prosecution witnesses was unreliable and untrustworthy as they offered no explanation for the injuries that these people had sustained. 
2. The complainant’s six individuals, including Indal Singh and Ramraj Singh, who were found guilty by the trial court of violating Section 396 IPC, were the subject of a cross-case, the attorney pointed out. The appellant said that this conviction undermined the prosecution’s case and implied that the appellant had acted in self-defense by proving that the complaint party’s members were the aggressors.
3. Raj Kumari and Indal Singh were said to be biassed and interested witnesses who were connected to the late Kaptan Singh. Therefore, in the absence of confirmation, their testimony was not credible. Counsel for the appellant asked the court not to accept their evidence in the absence of supporting documentation.
4. The incident, which included a lot of cross-firing, did not result in any injuries to the appellant. This was used as evidence to cast doubt on the prosecution witnesses’ credibility by suggesting that they did not give the whole story of what happened.
5. The attorney emphasised that Ramraj Singh’s evidence was not used by the High Court. This witness was not medically tested despite his claims to have been shot by the appellant, and his testimony did not match Chutallu @ Ram Mohan and Shiv Singh’s injuries.
6. It was argued that despite the statements of Raj Kumari, Indal Singh, and Ramraj Singh having contradictions and the High Court only partially believing them, the trial court incorrectly relied on their testimony to condemn the appellant. The appellant should be granted the benefit of the doubt and his right to a private defence, according to the counsel, who made this argument in light of the aforementioned points.

CONTENTION OF RESPONDENT

1. The points made by the appellant’s counsel were sharply contested by the State’s knowledgeable attorney. The respondent’s attorney said that the prosecution’s case rested on reputable and trustworthy evidence that the trial court and the High Court had both carefully considered.
2. The defence attorney for the respondent argued that the prosecution’s witnesses, especially Raj Kumari and Indal Singh, provided consistent and trustworthy testimony. These witnesses attested to the appellant’s activities during the event directly and were present at the scene.
3. The respondent argued that the medical evidence adequately explained and supported the injuries incurred by the deceased and the wounded witnesses. The complainant party’s self-defence resulted in any injuries that the appellant and his friends suffered, as demonstrated by the prosecution’s well-constructed sequence of events.
4. The respondent drew attention to the fact that the High Court had recognised the complaint party’s members’ right to self-defence and had cleared them in the cross-case. After the acquittal became final, it was concluded that the appellant’s side had initiated the altercation.
5. The State said that the prosecution’s evidence, which comprised medical records and eyewitness accounts, was coherent and supported one another. Based on a careful analysis of the circumstances, the trial court and the High Court properly evaluated the evidence and found the appellant guilty.
6. The appellant’s argument that the witnesses were biassed and so untrustworthy was denied by the respondent. Relatives of the victims are frequently witnesses in major crimes like this one, particularly when the crime happens at or close to their home. Their testimony was not immediately discounted because of their close closeness to the dead.
7. The appellant claimed to have acted in self- defence, but the State refuted this. The complaint party’s actions were defensive in character, since the evidence made it abundantly evident that the appellant and his friends were the ones who started the violence.
8. The respondent stressed that after carefully reviewing the material, the trial court and the High Court concluded that the appellant’s claims lacked substance. The decisions were specific and supported by substantial evidence, making it impossible for the appeal court to get involved. The respondent’s attorney asked the court to reject the appeal, affirm the lower courts’ rulings, and keep the appellant’s conviction and sentence in place in light of the aforementioned arguments.

JUDGEMENT

The appeal against the Madhya Pradesh High Court’s July 27, 2007, ruling, which maintained the appellant’s conviction for murder and attempted murder, is denied. The appellant received sentences of five years hard imprisonment and a fine for the attempted murder of Indal Singh under Section 307 IPC, and life imprisonment and a fine for the murder of Kaptan Singh under Section 302 IPC. The appellant was put on trial for the killings of Kaptan Singh and Kalyan Singh as well as the two occasions on November 10, 1985, when Indal Singh was attempted to be killed. Due to shaky eyewitness testimony, the trial court cleared the appellant for the murder of Kalyan Singh but found him guilty for the murder of Kaptan Singh and the attempted murder of Indal Singh based on testimony from Raj Kumari, Indal Singh, and Ramraj Singh.

The defence contended that the prosecution’s evidence was made up, pointing to a cross-case in which members of the complainant party were found guilty and implying that they were the ones who had caused the injuries to the appellant’s side during the event. The High Court did point out that there was no clear connection between the accusations in the cross-case, which involved Section 396 IPC. In this cross-case, the High Court found that the complaining party members were acting in self-defence and cleared them.

After reevaluating the case, the High Court determined that the appellant and his friends were the ones who started the shooting, and that the event happened at Kaptan Singh’s home. Raj Kumari and Indal Singh gave reliable, consistent testimony that were backed up by medical data. The court acknowledged the reliability of family members’ testimony in serious crimes committed at their home, rejecting the defence’s claims regarding partisan witnesses. Small discrepancies in the evidence were considered unimportant. The trial court’s convictions and punishments under Sections 302 and 307 IPC are upheld, and the appeal is rejected.

ANALYSIS

The reliability of eyewitnesses is crucial to the legal system. In this instance, the testimony of Raj Kumari and Indal Singh, who were present at the incident, was given substantial weight by both the trial court and the High Court. The courts determined that their stories were consistent and supported by medical evidence, despite the defence’s attempts to cast doubt on them because of their intimate relationship with the dead. This demonstrates how courts evaluate the credibility of witnesses by taking into account elements other than their personal connection to the victim, such as consistency and corroboration.

As this case demonstrates, the idea of self-defence is fundamental to criminal law. The appellant and his friends were defending themselves amid a violent brawl, according to the defence. Eyewitness accounts bolstered the prosecution’s case, which said that Indal Singh shot in self-defence, killing Shiv Singh and Chutallu @ Ram Mohan. The fact that the High Court upheld this story highlights how legitimate self-defence is recognized as long as it is supported by solid proof. One important feature was the existence of a cross-case in which members of the complaining party were found guilty in accordance with Section 396 IPC. This was utilized by the defence to claim that the aggressors were the side making the complaint. But the High Court distinguished between the accusations in the current case and the cross-case, emphasizing the evidence related to the particular occurrence. This method guarantees that every case is evaluated on its own merits and highlights the significance of context-specific evaluation in judicial procedures.

The judicial commitment to a fair trial is demonstrated by the trial court’s and the High Court’s intensive cross-examination of witnesses and careful reappreciation of the evidence. The courts made sure that the decision was founded on a thorough review of all relevant evidence by closely examining the testimony’s consistency, the existence of injuries, and the chronology of events. The case demonstrates the use of judicial discretion in assessing the evidence and witness statements. The trial court’s decision to find the appellant guilty of Kaptan Singh’s murder based on credible testimony yet exonerate him of Kalyan Singh’s murder owing to untrustworthy witnesses demonstrates rigorous judicial analysis. This judgment’s affirmation by the High Court highlights the appellate system’s tiered review procedure even further.

CONCLUSION

This case demonstrates how the legal system evaluates facts, witness reliability, and claims of self-defence in a thorough manner. The consistent and confirmed testimony of Raj Kumari and Indal Singh was given significant weight by the courts, underscoring the significance of trustworthy eyewitness statements. The judiciary’s meticulous consideration of the particular environment in which each case is evaluated on its own merits was evident in the distinction made between the cross-case and the current case. The trial court’s choice to condemn the appellant for the murder of Kaptan Singh based on solid evidence and to clear him of the murder of Kalyan Singh owing to untrustworthy witnesses highlights the trial court’s thoroughness and judgment. The appellate system’s tiered review procedure is further highlighted by the High Court’s endorsement of this decision.

The case serves as more evidence of the legal concept of self-defence, as courts have upheld the right to protect oneself and others when supported by solid proof. The thorough reappreciation of evidence and the prolonged cross-examination of witnesses demonstrate the judiciary’s dedication to a fair trial. Overall, the way the law was used in this instance emphasizes the values of justice, equity, and careful consideration of all relevant factors. This strengthens the credibility of the criminal justice system in rendering unbiased decisions that are grounded on in-depth investigation.

REFERENCE 

1. SCC Online.
2. India Kanoon

This article is written by Shivansh Raj student of Tamil Nadu National Law; Intern at Legal Vidhiya.

Disclaimer: The materials provided herein are intended solely for informational purposes. Accessing or using the site or the materials does not establish an attorney-client relationship. The information presented on this site is not to be construed as legal or professional advice, and it should not be relied upon for such purposes or used as a substitute for advice from a licensed attorney in your state. Additionally, the viewpoint presented by the author is of a personal nature.