Accident Register Entries Made By Doctor Who Treated Victim Can’t Override Unassailable Eyewitness Account: Madras High Court
The Court relied on settled precedent to hold that doctors are not required to conduct detailed enquiries into the occurrence while recording medico-legal entries.
The Madras High Court has held that entries made in an Accident Register by a doctor, while attending to a critically injured person, cannot be treated as conclusive or used to discredit an otherwise reliable eyewitness account.
The Court was hearing a criminal appeal filed under Section 374(2) of the CrPC challenging the conviction of the appellant under Sections 342 and 302 of the Indian Penal Code.
A Division Bench comprising Justice N. Anand Venkatesh and Justice P. Dhanabal observed: “… accident register cannot become a gospel truth to lay the entire case of the prosecution based on such accident register, … it is only a relevant piece of evidence, which can be acted upon to understand the treatment that was given by the Doctor to the injured/deceased taken to the hospital and the nature of the injuries sustained and the further course of action taken by the Doctor.
The entries made in the accident register need not be elevated to the status of a statement in order to develop the case from the accident register”, the Bench added.
Advocate G. Karuppasamy Pandian appeared for the appellant, while Additional Public Prosecutor A. Thiruvadikumar appeared for the State.
Background
The prosecution's case was that the accused, husband of the deceased, developed suspicion regarding her fidelity, which led to matrimonial discord. The deceased had shifted to her parental home along with her children.
On the date of the occurrence, while the deceased was proceeding along with her parents, the accused allegedly intercepted her, pulled her aside, and attacked her with a knife, causing fatal injuries. The parents of the deceased (PW1 and PW2) claimed to be eyewitnesses to the occurrence.
The injured was taken to the hospital, where she was attended by PW8 – Doctor, who prepared the Accident Register. She was subsequently referred to a higher medical facility but succumbed to injuries on the way.
The trial court, upon appreciation of evidence, convicted the accused under Sections 342 and 302 IPC, leading to the present appeal.
Court’s Observation
The principal issue before the Court was whether the entries made in the Accident Register, which indicated a version differing from the eyewitness account, could discredit the testimony of PW1 and PW2.
The Court examined the evidentiary value of entries made in Accident Registers and relied upon settled principles laid down by the Supreme Court. It reiterated that a doctor’s primary duty is to provide immediate treatment to the patient and not to conduct a detailed inquiry into the circumstances of the offence.
The Court observed that entries in such registers are made routinely and cannot be treated as substantive evidence of the occurrence. It further held that such entries do not amount to a detailed statement and cannot override direct evidence.
The Court referred to Saranraj v. State rep. by its Inspector of Police, K7 Police Station, Chennai (2018), in which the Madras High Court had previously held that “the Doctor is not at all concerned as to who committed the offence or whether the person brought to him is a criminal or to record any finer details about the case and what the Doctor is concerned about is to treat the patient and while doing so, the Doctor has to merely make the entry and fill up the columns provided in the Accident Register”.
The Court noted that the evidence of the parents of the deceased provided a clear and consistent account of the incident. Their testimony was found to be credible and remained unshaken in cross-examination.
The Court further held that the Accident Register and the testimony of the doctor, rather than contradicting the prosecution's case, actually corroborated the fact that the accused was responsible for the fatal injuries inflicted on the deceased.
It was also observed that minor discrepancies relating to place or timing, as reflected in medical records, cannot be elevated to create reasonable doubt when the core prosecution case is otherwise established through reliable eyewitness evidence. The Court emphasised that the benefit of doubt must arise from a reasonable and holistic assessment of the entire evidence and not from isolated inconsistencies.
The Court concluded that “considering the serious condition of the deceased and considering the fact that a Doctor will only focus on giving treatment to the person who is in a critical condition, every other entry made in the Accident Register cannot be taken to be a gospel truth and it cannot be pitted against the unassailable eyewitness account to disbelieve the same. In fact, the evidence of PW8 and the Accident Register.”
By no stretch, the entries made in an accident register, which is spoken to by a doctor can be used to completely discredit an eyewitness account, which is otherwise unassailable”, the Court added.
Conclusion
The High Court held that the prosecution had successfully proved its case beyond a reasonable doubt and that the reliance placed by the trial court on the eyewitness account was justified.
Accordingly, the Court dismissed the appeal and confirmed the conviction and sentence imposed upon the accused.
Cause Title: Muthukumar v. State rep by The Inspector of Police, Parthibanoor Police Station, Ramanathapuram District