Case title:
Dakkata Balaram Reddy vs State of Andhra Pradesh
Date of Order:
21st April 2023
Bench:
Justice Sanjay Kumar and Dinesh Maheshwari
Parties:
Petitioner: Dakkata Balaram Reddy
Defendant: State of Andhra Pradesh
Facts:
- Vetcha Kesava Rao (PW-1) claimed that A1, a civil contractor, and A2, an ex-serviceman and A1's brother-in-law, broke into his home, brutally murdered his wife and son, and then stole gold jewellery and money.
- After PW-1 reported the crime, A1 and A2 were apprehended by the police, and the stolen goods were recovered. The accused was found guilty of violating Sections 302, 397, and 450 of the IPC after the prosecution cross-examined 27 witnesses and submitted evidence.
- Under Section 302 IPC, among other punishments, they received a life sentence.
- The High Court rejected the accused's appeal after determining that the circumstantial and medical evidence was adequate to show that the accused intended to cause death.
- According to Article 136 of the Constitution, the case is currently up for appeal.
Arguments:
- When the Trial Court and High Court have issued concomitant findings of guilt against the accused, the Supreme Court has emphasised the narrow scope of jurisdiction under Article 136 of the Constitution. It was indicated that the Court would not challenge each factual conclusion in such an appeal or use it as a different forum for reevaluating the evidence. Only extreme unfairness, serious bias, or injustice brought on by mistakes in the law, the process, or the interpretation of the facts warrants interference.
- The Court reaffirmed that Article 136 does not guarantee the right to appeal but instead gives the Court discretion to intervene in circumstances where a grave injustice has been caused by illegality, misapprehension, an error in the interpretation of the evidence, or incorrect management of tangible evidence.
- The Supreme Court emphasised that there are no eyewitnesses in the current case, and the case is supported only by circumstantial evidence. In such cases, the chain of evidence must be thorough and exclude any conceivable reasons for the judgement that the accused is innocent. For the Court to find the accused guilty, the accused must be proven guilty and not simply maybe guilty, and the established facts must only support the accused's guilt.
- Both of the deceased died from shock brought on by brain damage and hemorrhage brought on by head injuries, according to the Supreme Court's analysis of the evidence, and their deaths were homicidal in nature. PWs 4, 6, and 10 are three different witnesses who saw one or both of the accused fleeing PW-1's home at the time of the incident. A1 was seen leaving PW-1's home by PW-4, PW-6, and PW-10 while A1 and A2 were both seen leaving the residence while carrying luggage by PW-10. Although PW-7 testified about the crime scene and told PW-1 about the incident, she did not mention the presence of the accused.
- The police detained the accused and seized cash and gold ornaments; the court further determined. Both defendants' bloodied clothing was also taken.
- Due to procedural errors, such as not following the rules while extracting chance prints and capturing samples fingerprints of the accused, the fingerprint evidence was judged untrustworthy and therefore not given any weight.
- The Supreme Court noted that there were inconsistencies and contradictions in the prosecution's case, including varying witness accounts, a lack of supporting evidence, and a hazy retrieval of the accused's clothing. It did point out, nevertheless, that some discrepancies in testimonies are to be expected given the passage of time. The court made it clear that barring a blatant injustice, it would neither reexamine the evidence nor conduct a roving investigation into factual concerns.
- The Supreme Court determined that while PW-1 followed the established protocol, his identification of the gold ornaments during the TIP raised no red flags. A2 was discovered in possession of a bag containing some of the stolen ornaments, but he was unable to provide any information regarding how he arrived to be in possession of them. A1's confession was admissible under Section 27 of the Indian Evidence Act of 1872 since he admitted to the crime's commission and helped locate the stolen gold jewels. There was no space for doubt due to the cumulative weight of the available evidence, which pointed to the accused's guilt.
Analysis:
- The defendants in this case were charged with robbing a jewellery store of gold ornaments weighing approximately 3.543 kg and cash worth Rs. 18,340. The defendants were found guilty of crimes punishable by Sections 302, 397, and 450 of the IPC, and the Additional District and Sessions Judge, Sompeta, punished them accordingly.
- When the Telangana High Court and the Andhra Pradesh High Court dismissed the two accused's appeal in a judgement in 2018, their conviction and sentence were confirmed. Both accused appeared before the Supreme Court because they were both resentful of the same.
- The accused were alleged of murder, but no sufficient ground to convict them as murderers were found.
- The court also claimed that the prosecution's case contained some inconsistencies and contradictions, that the order of events at the scene of the crime was unclear, and that the witnesses' accounts of when the police arrived and what they saw and said were inconsistent. Therefore, the application stands dismissed.
Conclusion:
In a recent case, Dakkata Balaram Reddy & Associates v. State of Andhra Pradesh & Associates the appeal was dismissed. The case was established on circumstantial evidence because there were no eyewitnesses. In such cases, the chain of evidence must be thorough and exclude any conceivable reasons for the judgement that the accused is innocent. For the Court to find the accused guilty, the accused must be proven guilty and not simply maybe guilty, and the established facts must only support the accused's guilt.
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