Issue Of Non-Payment Of Wages Is So Trivial A Matter So As To Compel Anyone To Commit Murder: SC Acquits Murder Accused

The Apex Court was considering an appeal filed by the appellant convict who was booked under Section 302 IPC for murdering one Ramlal. He had been awarded life imprisonment.

The Division Bench comprising Justice Pankaj Mithal and Justice Ahsanuddin Amanullah said, “The issue of non-payment of wages is hardly material and is so trivial a matter so as to compel anyone to take an extreme step of committing a crime of such a grave nature. Moreover, there is no material evidence to prove any discord between the two.”

AOR Rukhsana Choudhury represented the Appellant while Advocate Abhishek Pandey represented the Respondent.

Factual Background

It was alleged that the appellant was residing with the deceased and was assisting him in his work. On the fateful day, the appellant left for his native place on a cycle with a bag but returned after 2 hours claiming that his cycle got punctured. The appellant asked the wife of the deceased for some money to get the puncture repaired. In order to earn money, she went to the market to sell the paddy leaving the appellant and her husband at home. When she returned, she saw the appellant fleeing with a farsi in his hand and discovered that her husband was lying on the floor, profusely bleeding with his neck severed.

It was alleged that the relationship of the appellant with the deceased was strained probably on account of nonpayment/untimely payment of his wages. The appellant was the person last seen in the company of the deceased and the weapon of recovery i.e., farsi was recovered at his pointing out. The injuries sustained by the deceased were opined to have been caused by the weapon recovered. In these circumstances, the appellant was convicted and sentenced by the lower Courts.

Reasoning

The Bench took note of the fact that the prosecution was based on circumstantial evidence. The Bench noticed that the law with regard to a case based purely on circumstantial evidence stands crystalised by the decision in Sharad Birdhichand Sarda vs State of Maharashtra (1984) wherein five golden principles known as panchsheel proof of a case based on circumstantial evidence were enshrined. It was stated therein that the circumstances from which the conclusion of guilt is to be drawn should be fully established, the facts established should be consistent with the hypothesis of the guilt of the accused and the circumstance should exclude every other possible hypothesis except the one to be proved i.e., the guilt of the accused. It was also noted therein that there must be a chain of evidence so complete as not to leave any reasonable ground for conclusion that the accused is innocent and must show that in all human probability the act must have been done by the accused.

In light of such established principles, the Bench said, “ In other words, the chain of events leading to the prosecution of the convict must conclusively be established with certainty and there shall not be any room for any second opinion which may lead to the innocence of the accused.”

The appellant was said to have a motive to kill the deceased. The alleged motive was that he was living as a servant of the deceased for the last two months and there was some discord between him and the deceased in connection with non-payment/untimely payment of wages. The Bench clarified, “However, such a discord is not of such a nature of extent which may lead to such a drastic action on part of the appellant to kill the deceased.”

Coming to the aspect of ‘last seen together’, the Bench noted that the fact that the appellant-accused actually returned as alleged was not established by any independent evidence except for the statement of the wife of the deceased. However, her statement could not be corroborated by any piece of evidence. The cycle of the appellant was recovered by the police but no effort was made to find out if either of the tyres was punctured, which could have proved that the appellant may have returned as the cycle’s tyre got punctured.

The weapon of crime i.e., farsi was set to have been recovered after 20-25 days of the incident on the pointing out of the appellant. It had come in evidence that it had some blood stains. However, no forensic report was brought on record to prove that the blood stains on it matched that of the blood of the deceased. “Merely for the reason that the doctor opined that the injuries on the deceased may have been caused by a similar weapon would not conclude that the recovered farsi was the weapon of crime”, it added. It was stated by the wife of the deceased that when she returned home after selling the paddy, the appellant had fled. This meant that she had not found and seen the appellant at the place of the crime after her return as he had already fled. As per the Bench, it couldn’t be conclusively established that the witness saw the appellant running or fleeing from the place of crime. Moreover, no forensic report was produced to prove that the blood of those stains matched with the blood of the deceased.

Thus, the Bench allowed the appeal as the circumstances raising a finger upon the appellant, were not conclusive to prove beyond the shadow of a doubt that the appellant was the person responsible for the commission of the crime. The possibility of innocence of the appellant wasn’t excluded as per the chain of events. Setting aside the impugned orders of conviction, the Bench acquitted the appellant after noting that he had already suffered incarceration for over 10 years.

Cause Title: Hansraj v. State of Chhattisgarh (Neutral Citation: 2025 INSC 178)

Appearance:

Appellant: AOR Rukhsana Choudhury

Respondent: Advocate Abhishek Pandey,AOR Prashant Kumar Umrao

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