Justice BR Gavai & Justice Augustine George Masih, Supreme Court
Enmity Is A Double-Edged Weapon; Possibility Of Being Falsely Implicated Can’t Be Ruled Out: Supreme Court Acquits Murder Accused
|The Supreme Court set aside the Order of the High Court, which upheld the conviction of the Appellant under Section 302 of the IPC.
The Supreme Court acquitted a man convicted of murder while remarking that the possibility of being falsely implicated on account of previous enmity cannot be ruled out in the case.
The Court quashed and set aside the Order of the Madhya Pradesh High Court which upheld the conviction of the Appellant under Section 302 of the IPC as imposed by the Trial Court.
A Bench of Justice BR Gavai and Justice Augustine George Masih held, “It is a settled law that enmity is a double-edged weapon. On one hand, it provides motive, on the other hand it also does not rule out the possibility of false implication. From the nature of the evidence placed on record by the prosecution, the possibility of the present appellant being falsely implicated on account of previous enmity cannot be ruled out. In our opinion, therefore, the appellant is entitled to benefit of doubt.”
Senior Advocate Sanjay R. Hegde represented the Appellant, while AOR Mrinal Gopal Elker appeared for the Respondent.
Brief Facts
The Prosecution alleged that there was an altercation between the Appellant and the deceased where the Appellant attacked the deceased with a butcher knife (baka), causing fatal injuries on his neck, hands, and thighs. The injured victim was taken to the hospital, where he succumbed to his injuries. The police arrested the Appellant and recovered a blood-stained knife from his house. The Trial Court convicted him, sentencing him to life imprisonment, and the High Court upheld the conviction.
Court’s Reasoning
The Supreme Court noted that the Prosecution had relied on the testimony of the brother of the deceased, who it stated was an “interested witness.”
“No doubt that merely a witness being an interested witness cannot be a ground for discarding his testimony. However, the evidence of such a witness is required to be scrutinized with greater caution and circumspection. From the perusal of the evidence of Shahid Khan (PW-1), we do not find that the testimony of this witness is the one which would inspire confidence,” the Bench explained.
“It has come in the evidence on record that the deceased Guddu was a history-sheeter and was facing many criminal cases including a case for attempt to murder. It has also come in the evidence of prosecution witnesses that there was a previous enmity between the deceased and the appellant,” the Bench remarked.
Consequently, the Court held, “The impugned judgment and order…passed by the High Court of Madhya Pradesh at Jabalpur…and the judgment and order…passed by the trial court…are quashed and set aside…The appellant is acquitted of all the charges levelled against him.”
Accordingly, the Supreme Court allowed the Appeal.
Cause Title: Aslam Alias Imran v. State Of Madhya Pradesh (Neutral Citation: 2025 INSC 403)
Appearance:
Appellant: Senior Advocate Sanjay R. Hegde; AOR Prathvi Raj Chauhan; Advocates Prakash Sharma, Bittu Kumar Singh and Meghraj Singh
Respondent: AOR Mrinal Gopal Elker