Ramalingam vs. N. Viswanathan
Citation: 2024 INSC 45; Criminal Appeal No. 212 of 2024
Bench: Justice Abhay S. Oka, Justice Ujjal Bhuyan
Background
This case arose from a property dispute between Ramalingam and N. Viswanathan’s family. On October 9, 2004, during a court-ordered property survey, an altercation occurred, leading to the death of Siddammal (respondent’s mother). The respondent’s father lodged an FIR alleging that the appellants assaulted Siddammal, causing her death, and sought their prosecution for murder and related offences. The investigation concluded that the death was due to natural causes, not homicide, and the Sessions Court discharged the accused under Section 227 CrPC. However, the High Court, on revision, set aside the discharge and directed the trial to proceed, prompting the present appeal.
Supreme Court’s Analysis
Expert Medical Evidence:
The Supreme Court emphasized the significance of the post-mortem certificate and the testimony of Dr. R. Vallinayagam, the expert who conducted the autopsy. The doctor, examined by the complainant, categorically stated that there were no external injuries or ante-mortem wounds on the deceased’s body and that the death was natural, not caused by assault.
Absence of Prima Facie Material:
The Court observed that the only material supporting the prosecution’s case was the oral allegation of assault, which was directly contradicted by the medical evidence. There was no corroborative evidence, such as injuries consistent with the alleged assault, to justify framing charges for culpable homicide or murder.
Scope of Section 227 CrPC:
The Court reiterated that at the stage of discharge under Section 227 CrPC, the Sessions Court must consider whether there is sufficient ground for proceeding against the accused. In this case, the Sessions Court correctly found no such ground, as the prosecution’s own medical evidence ruled out homicidal death.
High Court’s Error:
The Supreme Court held that the High Court erred by ignoring the expert medical evidence and setting aside the discharge order. The High Court’s direction to proceed with the trial, despite the absence of material supporting the charges, was unsustainable.
Decision
The Supreme Court allowed the appeal, set aside the High Court’s order, and restored the Sessions Court’s order discharging the appellants. The Court concluded that there was no material to proceed against the accused, as the death was natural and not caused by criminal acts.
Significance
This judgment reinforces the importance of objective medical evidence in criminal cases, clarifies the scope of discharge under Section 227 CrPC, and cautions against proceeding to trial in the absence of prima facie material supporting the prosecution’s allegations.
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