State of Haryana vs. Mohd. Yunus
Citation: 2024 INSC 34; [2024] 1 S.C.R. 973
Bench: Justice M.M. Sundresh, Justice Prashant Kumar Mishra
Background
The case stemmed from an incident on January 9, 1999, in which Akbar was killed and three others—Deenu (PW-1), Ahmad (PW-2), and Harun—were injured. Four accused—Mohd. Yunus (A1), Mohd. Jamil (A2), Ghasita (A3), and Akhtar Hussain (A4)—were charged under Sections 302 and 323 read with Section 34 IPC. The trial court convicted A1, A2, and A3 for murder and causing hurt, while A4 was tried separately after surrendering and was acquitted. The High Court acquitted A1 (Mohd. Yunus) of murder but maintained his conviction for causing hurt, while upholding A2’s (Mohd. Jamil) conviction for murder. The State and the accused appealed to the Supreme Court, challenging the acquittal and conviction, respectively.
Supreme Court’s Analysis
Witness Testimony and Reliability:
The Supreme Court scrutinized the prosecution’s reliance on related and allegedly interested witnesses, noting inconsistencies and omissions in their statements. The Court observed that the prosecution failed to examine independent witnesses present at the scene, and there were doubts about the presence of the informant (PW-1) at the spot. The Court emphasized that in murder cases, conviction cannot rest solely on uncorroborated or unreliable testimony, especially when the evidence is marred by contradictions and omissions.
Delay and FIR Issues:
The Court agreed with the High Court that the arguments regarding delay or ante-timing of the FIR were not substantial enough to undermine the prosecution’s case, but found that the overall evidence was insufficient for a conviction under Section 302 IPC.
Assessment of Individual Roles:
The Court analyzed the roles attributed to each accused. It found that the evidence did not conclusively establish the common intention required for a murder conviction for A2 (Mohd. Jamil), and the medical evidence did not support the prosecution’s version regarding the fatal blows. The Court also noted that A1 (Mohd. Yunus) was rightly acquitted of murder by the High Court, given the lack of credible evidence against him.
Decision
The Supreme Court set aside the conviction of A2 (Mohd. Jamil) under Section 302 read with Section 34 IPC, while maintaining his conviction under Section 323 read with Section 34 IPC for causing hurt. The State’s appeal against A1’s acquittal for murder was dismissed. Since A2 had already served more than the sentence for causing hurt, his bail bonds were discharged.
Significance
This judgment reiterates that convictions in murder cases must be based on reliable, corroborated evidence. It underscores the judiciary’s caution in relying solely on interested or inconsistent witness testimony and highlights the need for independent corroboration in serious criminal trials.
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