Supreme Court Acquits Accused in Murder Case, Citing Weak Extra-Judicial Confession

Supreme Court overturned the conviction of Ramu Appa Mahapatar for the murder of his live-in partner due to lack of credibility in the extra-judicial confession and subsequent corroborating evidence, where the Trial Court had convicted the appellant under Section 302 of the Indian Penal Code (IPC), and the same was upheld by the High Court of Bombay.

Background: Ramu Appa Mahapatar (the appellant) was in a live-in relationship with Manda (the victim) and both of them were living in a Chawl it was alleged that there was a querelle between Manda and Ramu Appa and following which the appellant allegly have assaulted Manda and may have locked the door from outside and Manda later succumbed to the injuries. When the relatives of the deceased opened the door of the house which was bolted from outside, they found that Manda was lying dead with multiple bleeding injuries. An FIR was registered under section 302 IPC against Ramu Appa.

Ramu Appa was initially convicted by the Sessions Judge under Section 302 of the Indian Penal Code (IPC) and sentenced to rigorous imprisonment for life, the accused Ramu Appa appealed the conviction before the High Court of Bombay which upheld the conviction and sentence.

The prosecution's case was based on circumstantial evidence, primarily the extra-judicial confessions allegedly made by the appellant to various witnesses and the prosecution contended that the appellant had informed PW-1, PW-3, PW-4 and PW-6 that he had a quarrel with Manda and assaulted her with a grinding stone and stick, leading to her death.

The appellant's defense was that these confessions were unreliable, and there was no other evidence to link him to the crime and that the extra-judicial confession allegedly made by the appellant before the witnesses could not be accepted as a valid piece of evidence.

The Supreme Court examined the following

On "Extra-Judicial Confession" the Supreme Court reiterated that an extra-judicial confession is a weak piece of evidence and needs to be examined with great care and caution. The Apex Court emphasized that for an extra-judicial confession to be relied upon, it must be made voluntarily, truthfully, and in a fit state of mind.

The Court also noted that PW-3, the brother of the deceased, testified that the accused was in a confused state of mind when he allegedly confessed to the crime. This cast doubt on the voluntariness of the confession.

Supreme Court also found that there was a lack of other evidence to support the confession as there was no recovery of blood-stained clothes, the alleged murder weapon (grinding stone) was not recovered and there was no blood on the recovered stick that matched the blood of the deceased.

On pointing out the material omissions and inconsistencies in the testimonies of PW-3 and PW-6, the Apex Court found the inconsistency as they stated that the police did not record their statements accurately regarding the appellant's confessions.

The Court further observed that the statements of PW-3 and PW-6 under Section 161 Cr.P.C (Code of Criminal Procedure) were different from their evidence in court regarding the appellant's confession. The Court clarified that an omission in a police statement can amount to a contradiction if it is significant and relevant.

The Apex Court noted the unusual and strange reaction of the accused and acknowledged that there was a strong suspicion against the appellant, however emphasized that suspicion cannot replace hard evidence. Thus, the Supreme Court while considering the weak circumstantial evidence, the lack of credibility of the extra-judicial confessions, and the material contradictions, held that the appellant was entitled to the benefit of doubt. thereby allowed the appeal and set aside the High Court's judgment and acquitting the appellant.

Coram: Justice Abhay S. Oka And Justice Ujjal Bhuyan
Between: Ramu Appa Mahapatar vs The State Of Maharashtra
Date of Judgment: 04-02-2025