10 February 2025 Acquittal >> Criminal Law   |   Criminal Appeals & Suspension of Sentence >> Criminal Law   |   Evidence >> Criminal Law  

In a significant judgment of Ravi v/s The State of Punjab, the Supreme Court of India overturned the conviction of Ravi, who was sentenced to life imprisonment for the alleged murder of his first wife, Jamni. The case hinged on circumstantial evidence, which the apex court found to be insufficient and flawed.

Ravi, a laborer, lived with Jamni, his second wife Soma, and his two sons in a makeshift dwelling in Madh village, Amritsar. Jamni's death on August 22, 2014, triggered a police investigation based on a First Information Report (FIR) filed by Jamni's brother, Chaina Ram. The FIR alleged that Ravi, with the complicity of Soma, murdered Jamni by strangulation. Rajo, a neighbor, was initially named as a witness, claiming to have seen the murder.

The prosecution's case rested heavily on the testimony of Chaina Ram, Rajo, and Deep Chand (Jamni's cousin), along with the post-mortem report and the investigation conducted by the police. However, a dramatic turn occurred when all three key witnesses – Chaina Ram, Rajo, and Deep Chand – were declared hostile, retracting their initial statements and claiming Jamni died of illness.

The post-mortem report indicated asphyxia as the cause of death, with ligature marks on Jamni's neck. However, the doctor who performed the autopsy admitted under cross-examination that asphyxia could also be caused by chronic tuberculosis, and the ligature marks might have been a result of transporting the body. This significantly weakened the prosecution's case.

The investigating officer's testimony regarding the recovery of a rope allegedly used in the crime also fell short. He conceded that similar ropes were commonly available, failing to conclusively link the recovered rope to the alleged murder.

The Supreme Court, in its analysis, emphasized the "five golden principles" of circumstantial evidence established in Sharad Birdhichand Sarda v. State of Maharashtra. These principles require that the circumstances be fully established, consistent with the hypothesis of guilt, conclusive, and exclude every other possible hypothesis. Critically, the chain of evidence must be so complete as to leave no reasonable doubt about the accused's guilt.

Applying these principles, the court found the prosecution's evidence lacking. The hostile witnesses, the ambiguous post-mortem report, and the inconclusive evidence regarding the rope failed to establish Ravi's guilt beyond a reasonable doubt.

The State argued that Section 106 of the Evidence Act placed the burden on Ravi to explain the circumstances of Jamni's death, as it occurred within his dwelling. However, the Supreme Court clarified that this burden shifts to the accused only after the prosecution has established a prima facie case. The court cited Anees v. The State Govt. of NCT, emphasizing that Section 106 cannot be used to compensate for the prosecution's failure to present sufficient evidence.

Furthermore, the court highlighted a crucial oversight by the lower courts: Ravi's statement under Section 313 of the Code of Criminal Procedure. Ravi stated that Jamni had been suffering from chronic tuberculosis and was undergoing treatment at Beas hospital. The prosecution failed to investigate this claim, neglecting to re-examine the doctor who conducted the post-mortem or produce any corroborating medical evidence.

The Supreme Court concluded that the prosecution had failed to prove Ravi's guilt beyond a reasonable doubt. The court stressed that when the evidence allows for two conflicting interpretations, the benefit of the doubt must be given to the accused. Consequently, the court set aside the High Court's judgment and ordered Ravi's immediate release from prison, where he had served over ten years.

The court also acknowledged the valuable contributions of the legal aid counsel, Ms. Sonia Mathur, and her assistant, Ms. Surbhi Bhardwaj. This case serves as a reminder of the importance of robust evidence and adherence to established legal principles in criminal trials, ensuring that justice is not only done but also seen to be done.