Recovery of Common Items Like Pesticide Bottle Insufficient to Prove Guilt Without Direct Link to Crime: MP High Court Acquits Appellants in Murder Case

In a recent judgement, High Court of Madhya Pradesh set aside the conviction of the appellants who had been sentenced to life imprisonment under Sections 302/34 of the Indian Penal Code (IPC). The appellants were accused of murdering one Hari @ Bhaggu by poisoning and strangling him, but the court found that the prosecution had failed to prove the case beyond reasonable doubt, primarily due to unreliable witness testimonies and insufficient circumstantial evidence.

“Mere recovery of common household items like pesticide bottles is insufficient to establish guilt unless corroborated by strong evidence linking it to the crime.”

The appellants were initially sentenced to life imprisonment based on circumstantial evidence, which the High Court later found to be insufficient and unreliable.

The case originated from the death of Hari @ Bhaggu, who was found dead under suspicious circumstances. The prosecution alleged that the appellants, Surajbai and Bhuribai, administered poison to the deceased and later attempted to stage a suicide by hanging his body. The trial court convicted the appellants based on circumstantial evidence, which included the recovery of a pesticide bottle and a rope from the appellants’ house.

The central issue was whether the prosecution had successfully established the appellants' involvement in the alleged murder through circumstantial evidence. The High Court carefully evaluated the circumstantial evidence, including witness testimonies, the forensic report, and the recovery of items from the crime scene. The court also scrutinized the testimonies of key prosecution witnesses, many of whom were found to have long-standing enmity with the appellants, raising doubts about the credibility of their statements.

1.    Reliability of Circumstantial Evidence: The prosecution's case rested on circumstantial evidence, which, according to legal precedents, must form an unbroken chain pointing solely to the guilt of the accused.
2.    Witness Credibility: Several prosecution witnesses, including family members of the deceased, had admitted enmity with the appellants, which led the court to question the impartiality of their testimonies.
3.    Forensic Inconsistencies: The post-mortem report indicated that the cause of death was asphyxia due to strangulation, not hanging, as originally alleged. Poison was found in the deceased's viscera, but no direct evidence linked the appellants to administering the poison.

The court found several contradictions and inconsistencies in the prosecution’s case, which created significant doubt regarding the appellants’ guilt.

•    Inconsistent Witness Testimonies: Key prosecution witnesses (P.W. 1, P.W. 2, P.W. 6) gave conflicting accounts about critical aspects of the case. Suresh (P.W. 7), who testified that he heard the deceased plead for his life, gave his statement five months after the incident, which the court found suspicious and unreliable.
•    No Clear Chain of Circumstantial Evidence: The court observed that while a pesticide bottle and a rope were recovered from the appellants’ house, these items were commonly found in the homes of agriculturists and did not conclusively link the appellants to the crime. The court further noted that the trial court had acquitted the appellants of charges under Sections 201 and 203 IPC, which pertain to causing the disappearance of evidence.
•    Doubts Over Last Seen Theory: The prosecution failed to prove that the deceased was last seen in the company of the appellants. The only witness who claimed to have seen the deceased returning to the appellants’ house did not mention this in his police statement, which was a significant contradiction.
•    Forensic Evidence Discrepancy: The forensic evidence indicated that the ligature marks on the deceased's neck were not consistent with suicide by hanging, but rather strangulation. The court also found that the presence of poison in the deceased’s body was insufficient to prove that the appellants administered it.

After analyzing the evidence, the court concluded that the prosecution had failed to establish the appellants' guilt beyond reasonable doubt. The contradictions in witness statements, unreliable circumstantial evidence, and faulty investigation led the court to acquit the appellants.
 

Date of Decision: October 16, 2024