Supreme Court Upheld Conviction; Reliance on Injured Eyewitnesses and Weapon Use

The appeal was preferred against the concurrent findings of the Trial Court as well as the High Court of Madhya Pradesh, which had convicted the appellants for killing a grandfather and inflicting injuries on his three grandchildren. The incident was that the accused, who were reportedly incited by the owner of a controversial land, went to the home of the deceased and his grandchildren to confront them over the worship of a deity on the aforementioned land. The confrontation turned into a fight in which the victims were attacked by the accused with weapons.

Supreme Court analyzed that the conviction of the appellants under Section 302 read with Section 34 of the Indian Penal Code (IPC) for murder was justified, especially in light of the defense's argument that there was no premeditation or intention to cause death, and that the fatal head injury sustained by the deceased could have been the result of an accidental fall. The Court noted that the statements of the injured grandchildren, being ocular witnesses, could not be rejected solely on the basis that they were related to the deceased.

The Apex Court noted that the prosecution has categorically established that the accused had intruded into the residence of the deceased carrying lethal weapons, with a clear intention to harm. Notwithstanding the defence argument regarding the lack of incised wounds on the deceased and that the fatal injury might have occurred due to a fall, the Supreme Court noted that the ocular witnesses had persistently described a blow to the head of the deceased.

The Court also emphasized that the medical evidence supported the injuries incurred by the deceased and the injured witnesses, and that the fatal injury was to a vital organ of the body, the head, caused with the reverse side of an axe by the aggressors who intruded into the victims' residence, clearly indicated the intention to cause death or grievous injury likely to cause death.

The Apex Court held that in a melee where victims were attacked with lethal weapons, there could be an expectation of minute details about who delivered which blow with which part of the weapon to be unrealistic. There was no reason found by the Supreme Court to intervene with the concurrent conclusions of the Trial Court and the High Court.

Accordingly, the appeal was dismissed, and the conviction and sentence passed on the appellants on a charge of murder and other allied offenses were sustained. The Apex Court reiterated that the prosecution had effectively proven the accused's guilt beyond reasonable doubt, using the continuous and credible ocular evidence of the injured witnesses, which was sufficiently corroborated by the medical evidence, dispelling the claim of a simple accidental fall resulting in death.

CORAM: JUSTICE SUDHANSHU DHULIA & JUSTICE K. VINOD CHANDRAN
BETWEEN: MAUKAM SINGH & OTHERS VS STATE OF MADHYA PRADESH 2025 INSC 435
DOJ: 02-04-2025