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CASE ANALYSIS - RAM NIWAS V. STATE OF HARYANA
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CASE ANALYSIS - RAM NIWAS V. STATE
OF HARYANA
AUTHORED BY
- MARTIN JEYA PRAKASH V Y[1]
ABSTRACT:
According to a theory put forward
by William Blackstone in 1769, it is
preferable for 10 criminal people to
go free than for one innocent person to suffer. The preceding assertion should
be true, as demonstrated by the Ram Niwas v. State of Haryana
case. The Indian Supreme Court ruled that an accused person cannot
be found guilty based solely on suspicion, regardless of the level of suspicion,
in the homicide case where it
cleared one accused person. The Sessions Court and the Punjab and Haryana High Court's earlier
rulings were rightfully overturned by the Supreme
Court. In ruling on the case, which was primarily based on an alleged extrajudicial confession and
circumstantial evidence, a Divisional Bench of the Apex Court of India, made up of Justices B. R. Gavai and P. S. Narasimha, applied
the presumption of innocence principle—which states that a person
is presumed innocent unless and until he is
proven guilty beyond
a reasonable doubt—and freed the man from all charges.
KEYWORDS: Homicide, Extra Judicial Confession, Presumption of Innocent
Principle, Supreme Court.
INTRODUCTION:
The
lawsuit dates back to 2003,
the year of the occurrence. In summary, the appellant
and the dead got into a fight, which upset the appellant. As a result, he
claimed to have committed murder, which he subsequently admitted to the deceased's attorneys. In 2005, the Sessions
Court found the appellant guilty based on his extrajudicial confession and
further evidence, leading to his conviction. Through an appeal to the Punjab and Haryana High Court, he contested the Sessions
Court's ruling; nevertheless, that too was denied in 2009, leading him to file
an appeal with the nation's highest court. The
Indian Supreme Court considered a
number of factors and drew from a
number of precedents when rendering its decision in this case. It concluded
that there is insufficient evidence to prove the accused's guilt and that there
is at least some room for an inference that the accused is innocent. The extrajudicial confession is purported, but it cannot
serve as the only foundation for a conviction. The prosecution's case is
riddled with gaps and weak evidence that does not support
finding the accused
guilty of the crime. In other words, it was held
by the Supreme Court of India that, the accused ‘must be’ and not merely ‘may be’ guilty
before a court can convict.
FACTS OF THE CASE:
Pale was the son of Bhim Singh, the deceased brother of Ram Niwas, the
appellant, and Sunita, his sister. After the death of his spouse Pale,
Sunita moved in with her little boy to live at her parental home. Bhim Singh,
Deep Chand Singh, and Dilip Singh, who passed away, were brothers who want
Sunita to wed Rampal, the deceased's son. To continue their discussion
regarding Sunita's proposed second marriage to Rampal, the three brothers went
to her parents' home. After the deceased and appellant began
drinking alcohol in the evening,
there was talk about
remarrying Sunita to Rampal. After
hearing the proposition, the appellant became enraged, lost his composure, and
began insulting the dead. But the deceased's brothers, Bhim Singh and Deep
Chand Singh, stepped in and calmed the appellant. Following their meal
together, Ram Niwas lingered in the drawing room and requested Dilip Singh to join him for a conversation, while Bhim
Singh and Deep Chand Singh retired to bed
on the first floor. When Bhim Singh and Deep
Chand Singh returned to the drawing room the following morning, Dilip Singh was
not present. When they inquired about
the whereabouts of the deceased,
the appellant said that he had left
to respond to nature's call. They
enquired again about the location of the dead after waiting for thirty more
minutes, but they were not given a suitable response. Later, when Bhim Singh
and Deep Chand Singh arrived in the house's courtyard, they both detected the
stench of charred flesh—a human body. When they asked again about Dilip Singh,
Ram Niwas tremblingly said that the dead had intended to remarry Sunita to
Rampal. This infuriated Rampal, who then pushed Dilip Singh's throat and
strangled him to death. The corpse was set on
fire in an attempt to erase
the evidence, but it was not entirely destroyed and was hidden in Paraal (paddy
fodder). Afterwards, after removing the paddy straw, Deep Chand Singh and Bhim Singh discovered a partially burned body
wrapped in a plastic palli. They conveyed their displeasure to the appellant, who, upon hearing it, left
the site. The two brothers then returned, accompanied by others, to their
village. That same day, in the evening, the complainant filed a police report
(FIR).[2]
THE PROSECUTION'S SIDE:
Mr. Birendra Kumar Choudhary,
Lt. Additional Advocate General,
spoke on behalf of the State of Haryana.
i.
That
the accused was concurrently found guilty of the charges charged by both lower
courts, but only after a proper analysis of the available evidence.
ii.
That
in front of complainant Deep Chand
Singh and his brother Bhim Singh,
the accused delivered an extrajudicial confession.
iii.
That,
in accordance with section 27 of the Evidence
Act of 1872, the discovery of "ash" hidden inside a plastic
cover as the accused's memorandum supports the accused's extrajudicial
confession.
iv.
That none of the lower
courts will bring a lawsuit to overturn factual
findings.
COMMENTS FROM APPELLANT'S SIDE:
Ram Niwas, the accused/appellant, was represented by Ld. Advocate
On Record, Adv. Mr. Rishi
Malhotra. The submission was made:
i.
The
postmortem report makes it abundantly evident that Dalip Singh's dead corpse,
upon which the postmortem was performed, has not been shown to be his beyond a
reasonable doubt. The assertion is bolstered by the findings of the medical
examiner, Dr. Sanjeev Malhotra, who performed the post mortem on the deceased.
The report notes that the physician acknowledged that the deceased's face was
unrecognizably disfigured. The conviction was also unsupportable since there
was no evidence presented by the prosecution that Dilip Singh was the deceased
person.
ii.
That
Bhim Singh and Deep Chand Singh's testimony was untrustworthy and that the two
brothers' stated behaviours were incredibly abnormal.
iii.
Their
evidence clearly shows that after seeing the deceased corpse, they both
returned to their hamlet and returned in the evening.
iv.
That
the police station is just 1.5 km from the scene of the event, and that their failure
to notify the authorities of the occurrence right away casts substantial doubt
on the prosecution's case.
v.
The
right to an acquittal belongs to the accused/appellant.
VERDICT OF THE BELOW LEVEL COURT:
On January 12, 2005, the Sessions Court in Sonepat found the appellant
guilty of the offences covered by Sections 302 and 201 of the Indian Penal Code, 1860. The court
also sentenced the appellant to life in prison with rigorous
confinement and a fine of Rs. 5,000;
if the fine is not paid, he will be
subject to an additional two years of rigorous
imprisonment under Section 302 of the
Indian Penal Code. In contrast, the appellant was sentenced under section 201 to three years in jail, a fine of Rs. 2,000, and one year of hard
imprisonment should the fine not be paid. The two phrases were meant to flow simultaneously. High Court of Punjab and Haryana, on 16th of March,
2009, dismissed the appeal of the Appellant and upheld the rulings of the
Sessions Court.[3]
VIEWS FROM THE APEX COURT:
The court
noted that the accused is not sufficiently supported by evidence
to be found guilty of the allegations. The court cited the Sharad Birdhichand Sarda v. State of Maharashtra[4]
ruling, in which the law pertaining to conviction on the
basis of circumstantial evidence
has been crystallised and
made very clear, in
order to decide
upon the strength
and standing of circumstantial
evidence. The most fundamental and basic decision in this case was Hanumant v. State of Madhya Pradesh[5],
which is still widely followed and applied by courts in many subsequent
decisions. The court also considered other decisions regarding
the nature, character, and essential
proof required in a criminal case that
relies solely on circumstantial evidence. Moreover, the court provided five golden guidelines to
support a case based on circumstantial evidence, drawing on Hanumant v. State of Madhya Pradesh[6].
These guidelines are:
i)
It
is important to thoroughly determine the circumstances before determining
guilt. This time, the court outlines the conditions that include both "may
be" and "must be or should be." As indicated in the Shivaji
Sahabrao Bobade v. State of Maharashtra6 case, there is a distinction between
the two that goes beyond grammar. Specifically, the mental distance between
"may be" and "must be" is great and separates speculative
notions from conclusions that are necessarily drawn from them.
ii)
The
facts that have been proven should only support the theory that the accused is
guilty; in other words, they should not be consistent with any other theory
than the accused's guilt.
iii)
There
should be a decisive character and tendency to the circumstances.
iv)
They
ought to rule out all other theories in favour of the one that has to be
validated.
v)
The
chain of evidence must be so comprehensive as to preclude any plausible
inference that may support the accused's innocence and must demonstrate that
the accused was, within the bounds of human possibility, the one who committed
the offence.
In addition, the court took into
consideration the S. Arul Raja v. State
of Tamil Nadu[7]
case while determining the admissibility of extrajudicial confessions. In that case, it was noted that the idea of extrajudicial
confessions is essentially a judicial construct and should be utilised sparingly.
A confession of this nature ought to be employed sparingly and supported by a
great deal of prudence. The court ruling in Ram Singh v Sonia[8] established that an extrajudicial
confession made while under police custody is not admissible. Furthermore, the court must proceed with extreme caution
in cases involving extrajudicial confessions that are only supported
by circumstantial evidence. This court has upheld this idea in the cases of State of Maharashtra
Konidiba Tukaram Shirke[9] and Ediga Anamma v. State of Andhra Pradesh[10].
It is noteworthy to note that after arriving in Tamil Nadu, A-1 attempted to
repudiate this assertion. The prosecution was simply depending on the
"ash" that was found in the plastic bag on Ram Niwas's desk, which was
seized in accordance with Section 27 of the Evidence Act.
The
court ruled that before the accused may be found guilty, they "must be," not just "may be," guilty, and there must be a body of evidence that denies the accused's
innocence. It is a well-
established legal principle that suspicion, no matter how strong, cannot
substitute for proof beyond
a reasonable doubt, and that an accused
person cannot be found guilty based
solely on suspicion. The prosecution has failed to establish the sequence of events that leads to the sole conclusion that the accused is guilty. In addition to the circumstantial
evidence, the court declared that relying just on an alleged extrajudicial
confession as the foundation for the conviction would not be optimal. In light
of the aforementioned conclusions and findings, the Supreme Court of India
granted the appellant's appeal and declared that the rulings
and decrees of the Punjab and Haryana High Court and the Ld. Sessions
Court could not stand. The conviction verdict, as well as the rulings rendered
by the Punjab and Haryana
Sessions Court and High Court,
were overturned. The appellant/accused was released after
being found not guilty of any charges.
CONCLUSION:
Any court, regardless of level, that
hears a matter should correctly analyse it. The case's facts and the offered
evidence should be carefully examined
and taken into account. Because the element of suspicion was present, the
aforementioned instance was different from previous precedent. The nation's highest court issued a landmark decision that shed light on the reliability and validity of circumstantial
evidence, convictions based only on
suspicion, and the acceptance of extrajudicial confessions supported by
circumstantial evidence. As a landmark decision, the ruling will undoubtedly be used as a precedent in other instances involving
comparable facts and circumstances. In this instance, the five principles
outlined in previous precedents were utilised to evaluate circumstantial
evidence as proof in the matter and the sequence of events.
REFERENCE:
1.
MARTIN JEYA PRAKASH V Y STUDENT OF TAMILNADU DR AMBEDKAR LAW
3.
https://indiankanoon.org/doc/17423528/#:~:text=This%20appeal%20challenges%20the% 20judgment,by%20the%20learned%20Sessions%20Judge%2C
4.
https://indiankanoon.org/doc/17423528/#:~:text=This%20appeal%20challenges%20the% 20judgment,by%20the%20learned%20Sessions%20Judge%2C
5.
(1984) 4 SCC 116
6.
AIR1952SC343, 1953CRILJ129, [1952]1SCR1091
7.
1973 AIR 2622, 1974 SCR (1) 489, AIR 1973 SUPREME COURT 2622
8.
(2010) 8 SCC 233
9.
AIR 2007 SUPREME COURT 1218
10.
AIR1977SC278
11.
1974 AIR 799, 1974 SCR (3) 329, AIR 1974 SUPREME COURT 799
[1] MARTIN JEYA PRAKASH V Y STUDENT OF TAMILNADU DR
AMBEDKAR LAW UNIVERSITY (SOEL), CHENNAI, (EMAIL: itsmartin2001@gmail.com ; Mobile no: 8925166839)
[4] (1984) 4 SCC 116
[5] AIR1952SC343, 1953CRILJ129, [1952]1SCR1091
[6]
1973 AIR 2622, 1974 SCR (1) 489, AIR 1973 SUPREME COURT 2622
[7]
(2010) 8 SCC 233
[8] AIR 2007 SUPREME COURT 1218
[9] AIR 1977 SC 278
[10] 1974 AIR 799, 1974 SCR (3) 329, AIR 1974 SUPREME
COURT 799
Article Information
CASE ANALYSIS - RAM NIWAS V. STATE OF HARYANA
Authors: MARTIN JEYA PRAKASH V Y
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/04/11
- Issue 7
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International Journal for Legal Research and Analysis
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