Whether equal scrutiny applies to all accused in a case?

Facts of the Case

The case revolves around an incident on May 16, 2015, at Ananthapuram, where the appellant, George, allegedly murdered the son of the informant (PW-1) following a dispute related to church elections. The informant accused George and two others of abusing his son, chasing him, and fatally attacking him with a knife. The trial court convicted the appellant under Sections 294(b), 341, 302, and 506(ii) of the IPC. The Madras High Court upheld the conviction under Sections 294(b), 341, and 302 IPC but acquitted him under Section 506(ii). The appellant challenged this decision in the Supreme Court.

Contentions of the Appellant

The appellant argued that the High Court erred in convicting him based solely on the testimony of PW-1, which was deemed unreliable concerning the co-accused. He contended that the evidence lacked consistency and that the recovery of the knife, a key material object, was made from an open place accessible to anyone, reducing its evidentiary value.

Contentions of the Respondent

The State of Tamil Nadu contended that the conviction was based on a proper assessment of evidence and supported by material facts, including the testimony of PW-1 and the recovery of the weapon. They argued that the findings of the High Court were consistent with the evidence and did not warrant interference.

Issues of the Judgment
  1. Whether the conviction of the appellant based solely on the testimony of PW-1 is justified.
  2. Whether the recovery of the knife from an open place is sufficient to corroborate the charges.
  3. Whether the benefit of doubt granted to co-accused impacts the appellant’s conviction.
Observations/Findings by the Supreme Court

The Supreme Court found inconsistencies in the High Court’s reliance on PW-1’s testimony, which was deemed unreliable for the co-accused but accepted against the appellant. The Court highlighted that PW-1, being an interested witness, required greater scrutiny. The recovery of the knife from an open place was deemed insufficient to substantiate the charges. The Court concluded that the conviction was based on conjectures and lacked substantive evidence.

Principle of the Case

The principle emphasized in this case is that convictions in criminal cases must be based on credible and consistent evidence. Sole reliance on an interested witness, without corroborative evidence, is insufficient for conviction. Equal standards of scrutiny must be applied to all accused in the same case.

Final Order

The Supreme Court allowed the appeal, set aside the High Court’s judgment, and acquitted the appellant of all charges. The appellant was directed to be released immediately if not required in any other case. All pending applications were disposed of.

Impact on Public Law and Order

This judgment reinforces the principle of fair trial and the necessity for consistent and reliable evidence in criminal cases. It ensures that convictions are not influenced by conjectures or biased assessments, upholding the integrity of the judicial process. By acquitting the appellant, the Supreme Court has highlighted the importance of adhering to stringent evidentiary standards, promoting public trust in the judicial system.

Case Citation

Court Name: Supreme Court of India
Case Title: George v. The State of Tamil Nadu & Others
Case No.: Criminal Appeal No. ___ of 2024 (Arising out of SLP(Crl.) No. 5902 of 2021)
Date of Judgment: December 13, 2024
Judges: B.R. Gavai, J. & K.V. Viswanathan, J.

 

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