SUPREME COURT ACQUITS ACCUSED IN PUNE TRIPLE MURDER CASE

The Supreme Court acquitted a death row convict, held that motive alone is not sufficient for conviction in the Pune triple murder case.

The Supreme Court of India in Vishwajeet KerbaMasalkarvs.the State of Maharastrarecently acquitted the appellant in the 2012 Pune triple murder case, overturning the death sentence which was previously upheld by the Bombay High Court. The accused, who was convicted of murdering his wife, mother, and two-year-old daughter, was set free after the Supreme Court identified discrepancies in the prosecution’s evidence, casting substantial doubt on his guilt.

Facts of the Case

On October 4, 2012, the appellant reported to the police control room that his wife, mother, and daughter were murdered, and that valuables such as gold, mangalsutra, cash, and jewelry were stolen. He also mentioned that a neighbor was injured during the incident. Initially, the investigation focused on an unknown attacker, however the appellant was suspected of the murder after the police found out that the itemswhich were stolen were hidden in the appellant’s house, including gold jewelry, cash, and the mangalsutra.

on October 5, 2012, The Police arrested the appellant after discovering that the appellant have an extramarital affair. During the investigation, a divorce consent letter from his wife, blood-stained clothes, and the hammer allegedly used in the crime were found. Consequently, the trial court framed charges against the appellant for offenses under Sections 302, 307, and 201 of the Indian Penal Code (IPC). In 2016, the trial court sentenced the appellant to death, a decision which was later upheld by the Bombay High Court.

Issues Before the Court

1) Whether the appellant was responsible for the murder of his wife, mother, and daughter?

2) Whether the prosecution provided sufficient evidence to prove that the appellant’s guilt beyond a reasonable doubt?

3) Whether a conviction can be based solely on circumstantial evidence, especially when witness testimonies contain significant discrepancies?

 

Contentions by Both Parties

Contentions by the Appellant:

The appellant argued that the prosecution’s case heavily relied on the testimony of the neighbour, that contained numerous inconsistencies. The appellant highlighted that theneighbourstatement was recorded six days after the incident without any explanation for the delay. The defense also questioned the reliability of the blood-stained hammer and clothes. They contended that the evidence was insufficient to prove guilt beyond a reasonable doubt, and that the appellant was being wrongfully convicted based on suspicion and circumstantial evidence alone.

Contentions by the Prosecution:

The prosecution asserted that the appellant’s guilt was proven beyond a doubt, emphasizing the testimony of the neighbourand the recovery of the hammer and blood-stained clothes from the appellant’s home. They argued thatneighbour as an injured witness, should be given higher credibility. The prosecution also pointed to the appellant’s affair and the recovered items as supporting evidence of his guilt.

 Supreme Court’s Judgment

A three-judge bench comprising Justices B.R. Gavai, Prashant Kumar Mishra, and K.V. Viswanathan overturned the trial court and Bombay High Court’s decisions, citing major flaws in the prosecution’s case. The Court found the neighbour’stestimony, a key piece of evidence, to be full of contradictions and unreliable.

The Court noted that although the neighbourwas conscious and coherent when admitted to the hospital, his statement was delayed for six days, raising doubts about its credibility. Moreover, no other neighbors were called to corroborate withhimand there might be a possibility of tampering with the evidence. The Court observed thatneighbour’stestimony did not conclusively prove he had witnessed the crime. The Court reiterated the principle that the accused “must be” proven guilty beyond a reasonable doubt, and that a conviction cannot be based solely on the motive or suspicion. Since the prosecution failed to rule out other reasonable explanations, the testimony of neighbour was discarded, which rested purely on circumstantial evidence.

The Court emphasized that strong suspicion is not a substitute for proof beyond a reasonable doubt, especially in cases involving circumstantial evidence. In this instance, the prosecution failed to meet this standard.

Ratio Decidendi

The Supreme Court ruled that a conviction cannot be based solely on suspicion or motive. There must be credible evidence proving guilt beyond a reasonable doubt. The Court emphasized that the principle of “innocent until proven guilty” must be upheld, and mere suspicion cannot satisfy the legal threshold to convict a person.

Principle Established

The principle established in this case is that convictions based on circumstantial evidence must conclusively prove the guilt of the accused and eliminate any other reasonable hypothesis. Motive alone is insufficient for conviction, and there must be direct or corroborative evidence linking the accused to the crime. In this case, the prosecution failed to meet these requirements.

Conclusion

In this case, the Supreme Court’s decision to acquit the appellant highlights the importance of maintaining strict evidentiary standards in criminal cases, particularly those involving the death penalty. The ruling reinforces the principle that suspicion, no matter how strong, cannot replace proof. It also emphasizes the need for prosecution to establish guilt beyond a reasonable doubt, particularly in cases relied on circumstantial evidence. In this landmark judgment, the Supreme Court quashed the conviction and death sentence, it acknowledged the foundational legal principle that the accused “must be” proven guilty, not merely “may be” guilty, before a conviction can stand.Top of FormBottom of Form

 

Baddam Parichaya Reddy

The Indian lawyer & Allied Services