Motive Pales Into Significance When Direct Ocular Evidence Establishes Crime; Enmity Is A Double-Edged Sword: Allahabad High Court

"Law is well settled that enmity is a double edge weapon which can be used by either of the side. It can be a ground for false implication and it can be a motive for commission of crime... when ocular testimony inspires the confidence of the Court, the prosecution is not required to prove the motive, " Allahabad High Court, in a significant criminal ruling dated May 29, 2024, held that the absence or weakness of motive becomes inconsequential when direct eyewitness testimony is found to be reliable and trustworthy.

A division bench comprising Justice Salil Kumar Rai and Justice Dr. Ajay Kumar-II observed that while motive is critical in cases of circumstantial evidence, it "pales into significance" when direct evidence establishes the crime. The Court upheld the life imprisonment of a man convicted of a 1998 murder stemming from a protracted land dispute.

The case originated from a long-standing land dispute between the informant, Mahipal, and the family of the accused, which had been litigated since 1972. On April 10, 1998, Mahipal’s son, Jagpal, was intercepted while travelling on a bicycle and brutally attacked with sticks and knives by four individuals, including the appellant Pravesh. Jagpal succumbed to his injuries on the spot, and while several accused died during the pendency of the appeal, the case survived for adjudication against the appellant Pravesh.

The primary questions before the Court were whether the prosecution had successfully established a motive for the murder and if the absence of a motive for one specific accused would vitiate the conviction. The Court also examined whether the non-examination of a cited eyewitness and the failure of witnesses to sign the inquest report would be fatal to the prosecution’s case.

Motive Secondary To Direct Eyewitness Testimony

The Court delved deeply into the doctrine of motive in criminal jurisprudence, noting that its importance varies depending on the nature of the evidence. The bench emphasized that if the evidence of eyewitnesses is found to be truthful and convincing, the prosecution is under no legal obligation to prove a motive.

The Court referred to the Supreme Court’s ruling in Chandan v. State (Delhi Admn.), reiterating that the lack or absence of motive is inconsequential when direct evidence establishes the crime. In the present case, the presence of two eyewitnesses who consistently narrated the assault was sufficient to sustain the conviction regardless of the specific depth of the appellant's personal grudge.

Enmity Viewed As A Double-Edged Sword

Addressing the defense's argument regarding the bitter history between the parties, the Court observed that enmity is a "double-edged weapon." The bench noted that while enmity can be a ground for false implication, it simultaneously serves as a potent motive for the commission of a crime.

"It is more often than not that a relation would not conceal actual culprit and make allegations against an innocent person," the bench observed. The Court found that since the informant’s side had recently won a land auction against the accused’s family, the resentment on the part of the accused was a much stronger probability than the theory of false implication.

Non-Signing Of Inquest Report Not Fatal To Credibility

The defense had argued that the eyewitnesses were not present at the scene because they had not signed the inquest report or other police papers prepared on the spot. The High Court rejected this contention, clarifying the limited scope of Section 174 CrPC.

The Court held that the object of inquest proceedings is merely to ascertain the apparent cause of death and not to identify the assailants or record eyewitness statements. "The testimony of an eye-witness could not be discarded on the ground that their names did not figure in the inquest report prepared at the earliest point of time," the bench held, citing Radha Mohan Singh v. State of U.P.

Status And Reliability Of Related And Chance Witnesses

The Court addressed the challenge to the witnesses being "related" and "chance witnesses." It held that relationship to the deceased is not a factor that automatically discredits a witness. Instead, it often ensures that the witness would want the real culprit punished.

Regarding the "chance witness" label, the Court noted that as long as the witness adequately explains their presence at the location, their testimony cannot be eschewed. The bench found that the witnesses, who were going to hire labourers for harvesting, had provided a natural and plausible explanation for being on the road where the murder occurred.

FIR Is Not An Encyclopedia Of Facts

The Court dismissed the argument that the witnesses had "improved" the story by assigning a knife to the appellant in court when the FIR mentioned a stick. The bench reiterated that an FIR is not intended to be an encyclopedia containing every minute detail of the occurrence.

"If the necessary details are there, on its basis, detailed narrations by the witnesses cannot be doubted," the Court observed. It noted that the FIR did mention the use of knives and the presence of the appellant, and the detailed role attributed during the evidence was a natural progression of the trial process.

The High Court concluded that the medical evidence, which showed multiple incised wounds and skull fractures, perfectly corroborated the ocular testimony of the witnesses. Finding no merit in the appeal, the Court affirmed the trial court’s judgment of life imprisonment. The appeal was dismissed, and the appellant, who was already in jail, was ordered to serve out his remaining sentence.

Date of Decision: 29 May 2024