Supreme Court Highlights Failures in Criminal Justice System and Upholds Conviction in Politically Influenced Murder Case

In a landmark judgment, the Supreme Court of India has highlighted the alarming failures within the criminal justice system while upholding the conviction of accused-respondent no.2, Prabhunath Singh, under Sections 302 and 307 of the Indian Penal Code. The case involves a politically influenced murder and attempt to murder, shedding light on the importance of fair trials, impartial investigations, and the role of various stakeholders in the legal process.

The court's observations underscored the gravity of the situation, stating, "The Trial Court and the High Court miserably failed to notice the sensitivity and intricacies of the case. Both the Courts completely shut their eyes to the manner of the investigation, the Prosecutor’s role, and the highhandedness of the accused..."

The judgment revealed that the investigation had been tainted, showcasing the powerful influence of accused-respondent no.2, who held a prominent political position as a sitting Member of Parliament. The failure of key stakeholders, including the police, public prosecutor, and judiciary, to fulfill their responsibilities was strongly criticized. The court cited the conduct of the public prosecutor as being to the advantage of the accused, rather than ensuring a proper prosecution, and also pointed out that both the Trial Court and the High Court had ignored administrative reports that had raised concerns about the case.

The case revolved around a dying declaration – the Fard Bayan – of the deceased victim, Rajendra Rai, which was later converted into an FIR. The court found the declaration to be admissible in evidence and to be read as the victim's last statement. The medico-legal reports confirmed the cause of death to be homicidal, resulting from firearm injuries. The court also drew adverse inferences against the accused based on their subsequent conduct, further strengthening the case against them.

Additionally, the court invoked its power to take judicial notice of administrative reports and judgments that had criticized the conduct of the accused, the investigating agency, the public prosecutor, and the presiding officer of the trial. The court emphasized that these factors could not be ignored, as they were integral to understanding the fairness of the trial.

The conviction of Prabhunath Singh, accused-respondent no.2, under Sections 302 and 307 IPC, was upheld based on the dying declaration, corroborating eyewitness testimony, and subsequent conduct. The court, however, acquitted the other accused due to a lack of evidence connecting them to the crime. The judgment serves as a stern reminder of the challenges within the criminal justice system and the urgent need for reform to ensure fairness, transparency, and accountability. The court's decision has set a significant precedent, encouraging a critical examination of the functioning of the legal system and the role of various entities within it.

Date of Decision: August 18, 2023 

HARENDRA RAI vs THE STATE OF BIHAR & ORS.