Life Imprisonment Affirmed for Unlawful Assembly Leading to Murder

Key Judicial Interpretation:

The court held that minor inconsistencies in eyewitness testimonies do not discredit their overall credibility if the testimonies are largely consistent and corroborated by other evidence. The court emphasized the principles from Rammi v. State of M.P. and Tahsildar Singh v. State of U.P. on witness credibility and contradictions (paras 10-15).

Court’s View:

The court determined that the appellant’s act of stabbing the victim was intentional and premeditated, fulfilling the criteria for murder under Section 300 of the IPC. The evidence supported the prosecution’s case beyond a reasonable doubt, and the minor inconsistencies in witness testimonies did not undermine their reliability (paras 9-24).

Conclusion:

The Supreme Court upheld the appellant’s conviction for murder under Section 302 of the IPC, affirming the life imprisonment sentence and dismissing the appeal (paras 27-28).

Relevant Acts, Sections, Provisions, and Rules Cited:

Sections 143, 147, 148, 302, 324, 149 of the Indian Penal Code, 1860; Section 374(2) of the Code of Criminal Procedure, 1973; Section 134 of the Indian Evidence Act, 1872.

Case of the Appellant:

The appellant argued that the eyewitness testimonies were unreliable due to material contradictions and gaps, and that there was insufficient evidence to prove the intent to cause death. The appellant contended that the discrepancies in weapon descriptions and the hostile testimony of PW4 undermined the prosecution’s case (paras 5-6).

Appellant Relied On:

Rammi v. State of M.P.; Tahsildar Singh v. State of U.P.; Stalin v. State.

Case of the Respondent:

The respondent defended the conviction, arguing that the concurrent findings of the Sessions Court and the High Court were based on credible evidence and did not warrant interference. The respondent emphasized the consistency and reliability of the prosecution witnesses and the medical evidence (para 7).

Respondent Relied On:

Pulicherla Nagaraju @ Nagaraja Reddy v. State of Andhra Pradesh.

Question & Answer:

Question: What was the primary reason for the appellant’s conviction being upheld? Answer: The Supreme Court found the eyewitness testimonies credible and consistent with the medical evidence, establishing beyond reasonable doubt that the appellant intentionally caused the victim’s death (paras 9-24).

Question: How did the court view the discrepancies in the eyewitness testimonies? Answer: The court viewed the discrepancies as minor and not substantial enough to undermine the credibility of the witnesses (paras 10-15).

Question: What was the appellant’s argument regarding the intention to cause death? Answer: The appellant argued that the single stab wound was not sufficient to prove an intention to cause death. The court rejected this, noting the attack’s premeditated nature and the fatal location of the wound (paras 5, 23-26).

Question: Did the hostile testimony of PW4 affect the case’s outcome? Answer: No, the court found that PW4’s hostility did not significantly impact the prosecution’s case as other eyewitness testimonies were consistent and reliable (para 18).

Question: What did the medical evidence reveal about the cause of death? Answer: The medical evidence revealed that the victim died of hemorrhage caused by an incised wound on the apex of the heart, corroborating the eyewitness accounts of the stabbing (paras 16, 24).

Details of Case:

Court: Supreme Court of India Bench: Dipankar Datta J., Pankaj Mithal J. Date of Order: 08th July, 2024 Case Name: Joy Devaraj vs. State of Kerala Case No.: Criminal Appeal No. 32 of 2013