According to the top court, the prosecution must establish the accused’s guilt beyond a reasonable doubt in cases involving circumstantial evidence, which was not done in the immediate case.
In the case of Guno Mahto v. State of Jharkhand, the Supreme Court recently declared that the courts had wrongly convicted the man of killing his wife almost 22 years before on the basis of a mere suspicion. The man was sentenced to life imprisonment for his wife’s murder, noting that the orders finding him guilty were based on “incorrect and incomplete appreciation of evidence”, resulting in a travesty of justice.
Justices BR Gavai and Sanjay Karol, sitting as a divisional bench, believed that the only reason the appellant was convicted by the lower courts was because he was last seen with his deceased wife. It further stated that the circumstances connecting the appellant to the offence were not established in any way, much less beyond a reasonable doubt.
In a Sessions Trial, the Trial Court in Daltonganj convicted the appellant Guna Mahto guilty of killing his wife, Deomatiya Devi, in accordance with Section 302 of the Indian Penal Code, 1860. In accordance with Section 302 of the Indian Criminal Code, he was given a life sentence and two years of hard labour. Section 201 of the Indian Penal Code dealt with the other offence. The High Court upheld the Trial Court’s conclusion.
The incident occurred in 1988. In order to prevent the disappearance of any evidence linking the accused to the crime, the prosecution claimed that he killed his wife and dumped her body in the village well. Subsequently, the defendant addressed the police while still having dirty hands by inventing a hoax about his wife going missing.
Following an examination of the relevant facts, the Court cited the established rules of circumstantial evidence upheld in the famous case of Sharad Birdhichand Sarda v. State of Maharashtra.
The Court observed that there is no visual or documentary evidence supporting the fact that the accused destroyed evidence by providing information to the police in an effort to shield himself from prosecution for the death of his own wife.
The Court established from hearing the deceased’s father, Banaudhi Mahto (PW-2), testify that he had made no accusations against the accused in connection with the crime. Additionally, several prosecution witnesses gave statements that were either hearsay or unreliable. The Court concluded as a result that the circumstances connecting the accused to the crime were not at all substantiated.
The prosecution’s case is deemed questionable by the non-examination of the investigating officer, according to a bench comprising Justices BR Gavai and Sanjay Karol.
BY NEHA A. PARDESHI ON 4th APRIL, 2023
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