In a recent judgment, the Patna High Court underscored the critical importance of medical evidence when determining the nature of a death in criminal cases. The court ruled that the oral testimony of general witnesses, without corroboration from medical experts, is insufficient to establish a homicidal death. This decision came as the court upheld the acquittal of three women previously accused of murder.
Case Background
The case involved an appeal against a judgment from the Fast Track Court, which had acquitted three women charged under various sections of the Indian Penal Code, including Sections 147 (Punishment for rioting), 148 (Rioting, armed with deadly weapon), 149 (Every member of unlawful assembly guilty of offence committed in prosecution of common object), 307 (Attempt to murder), and 302 (Punishment for murder). The prosecution alleged that the accused were involved in a fatal altercation stemming from a dispute over plucking mangoes.
Trial Court Findings
The trial court acquitted the respondents, citing material contradictions in witness testimonies and the absence of crucial medical and forensic evidence. Notably, the prosecution failed to produce a postmortem or injury report and did not examine the doctor who conducted the autopsy. These omissions led the trial court to conclude that the prosecution had not proven its case beyond a reasonable doubt.
High Court's Analysis
Upon appeal, the Patna High Court's Division Bench, comprising Justice Rajeev Ranjan Prasad and Justice Jitendra Kumar, conducted a thorough review of the case. The court emphasized that establishing a homicidal death requires more than just the oral testimony of lay witnesses. Expert medical opinion is essential to determine the nature of injuries and the cause of death.
The court observed: "Oral evidence of general witnesses is not sufficient to prove the homicidal death on account of the alleged assault. It is only by a witness, expert in medical science, can opine regarding the nature of the injury and whether the death of the deceased was caused by such injury. But there is no such medical evidence on record and hence, the prosecution has failed to prove beyond reasonable doubts the homicidal death on account of the alleged injury."
Significance of Medical Evidence
The judgment highlights the indispensable role of medical evidence in criminal trials, particularly in cases involving alleged homicidal deaths. Medical reports and expert testimonies provide objective assessments of injuries and causes of death, which are crucial for the court's determination. Without such evidence, establishing the exact cause and nature of death becomes challenging, leading to reasonable doubt.
Discrepancies in Prosecution's Case
The court also noted significant inconsistencies in the prosecution's case. The informant's statements were contradictory, and there was a lack of clarity regarding the motive behind the alleged assault. The initial claim that the altercation occurred over plucking mangoes was not substantiated with credible evidence. These discrepancies further weakened the prosecution's case.
Appellate Jurisdiction Principles
In its judgment, the High Court reiterated the principles governing appellate jurisdiction in cases of acquittal. Citing the Supreme Court's decision in H.D. Sundara v. State of Karnataka, the court noted that if the trial court's view is a possible one, the appellate court should not overturn the acquittal merely because another view is also possible. This principle underscores the deference appellate courts must show to trial court findings, especially when based on assessments of witness credibility and evidentiary gaps.
Conclusion
The Patna High Court's ruling reinforces the necessity of comprehensive and corroborative evidence in criminal prosecutions. The absence of medical evidence proving the cause of death, coupled with inconsistencies in witness testimonies, led to the upholding of the acquittal. This judgment serves as a reminder of the prosecution's burden to establish guilt beyond reasonable doubt, relying on both eyewitness accounts and indispensable medical expertise to substantiate claims of homicidal death.
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