Deliberate Crushing Under Tractor Wheels Establishes Murder, Not Accident: Allahabad High Court Upholds Conviction Under Section 302 IPC

"Eye-Witness Testimony Cannot Be Rejected Merely Because the Witness Is a Relative" — Allahabad High Court delivered a significant ruling reinforcing the sanctity of eye-witness testimonies, particularly those from related witnesses, while upholding the conviction of the appellant under Section 302 IPC. The Court found that Dheer Singh, driving a tractor, intentionally ran over the deceased Mangat Singh in a family land dispute, categorically rejecting the defense of accidental death.

The case stemmed from a simmering family dispute over a passage ("rasta") between Mangat Singh’s family and that of the accused Dheer Singh. On 13th October 1981, following an earlier assault incident in the morning, the deceased and his son were en route to the police station to lodge a report when Dheer Singh, along with co-accused Yashpal (since deceased), intercepted them. It was alleged that Dheer Singh intentionally drove a tractor over Mangat Singh, causing his death on the spot. The Sessions Court had convicted Dheer Singh under Section 302 IPC in 1984.

The principal legal issues revolved around whether the act was an intentional murder or a mere accident, and whether the testimony of related witnesses could be relied upon.

The Court categorically noted: "Testimony of PW-1 Ramphal, an injured eye-witness, cannot be rejected merely because he is a related witness. He is a natural witness present on the spot."

Addressing the defense argument that no crushing injuries were observed, the Court emphasized: "Even in the absence of bone fractures, death due to crushing is medically plausible, especially on soft rural soil."

The Court heavily relied on the medical evidence provided by Dr. J.G. Garg and expert CW-1 Dr. Krishna Kumar Singhal, observing: "The injuries suffered by the deceased could very well be caused by being dashed and crushed under the wheels of a tractor."
On the question of motive, the Court noted: "Strong motive existed due to family enmity, and the chain of circumstances proved deliberate intention beyond reasonable doubt."

The Court affirmed that the deceased Mangat Singh was deliberately targeted. The evidence of PW-1 Ramphal (injured son of deceased) and PW-2 Pitamber Singh (independent eye-witness) was found trustworthy. The medical and site inspection corroborated the prosecution's version. The Court dismissed the theory of accident, finding it an attempt to evade murder liability.

The Bench observed: "The ocular evidence, medical findings, and expert opinion leave no room for doubt that the appellant had a clear intention to kill."

Reiterating the importance of injured witnesses' testimonies, the Court stated: "An injured witness comes with a built-in guarantee of his presence at the scene and his testimony deserves great weight."

Accordingly, the appeal was dismissed. Dheer Singh’s conviction under Section 302 IPC was upheld. His bail bonds were cancelled, and the CJM, Saharanpur, was directed to take him into custody forthwith.

The Allahabad High Court, applying settled legal principles, strongly upheld that eye-witness accounts from related or interested witnesses cannot be disbelieved merely on account of relationship if otherwise found credible. The ruling marks a firm stance against the casual undermining of such testimonies in cases involving serious crimes like murder.

Date of Decision: 28th April 2025