Case title:
Rajesh & Anr. V. State of Madhya Pradesh
Date of Order:
21th September, 2023
Bench:
Hon'ble Justice B.R. Gavai
Hon'ble Justice J.B. Pardiwala
Hon'ble Justice Sanjay Kumar
Parties:
Petitioner: Rajesh & Anr.
Respondent: State of Madhya Pradesh
SUBJECT
The court found that despite the numerous flaws and gaps in the prosecution's case, both the Trial Court and the High Court were not only willing to accept it at face value but also went so far as to sentence Rajesh Yadav and Raja Yadav to death and uphold that sentence.
IMPORTANT PROVISIONS
Section 302 of IPC- Punishment for murder
Section 120B of IPC- Punishment of criminal conspiracy
Section 364A of IPC- Kidnapping for ransom
OVERVIEW
- In the final week of July 2013, a 15-year-old boy named Ajit Pal @ Bobby was brutally murdered. In Sessions Case No. 560 of 2013, a neighbour named Om Prakash Yadav, along with his brother Raja Yadav and son Rajesh @ Rakesh Yadav, were on trial for Ajit Pal's murder and other related offenses.
- The learned Additional Sessions Judge, Jabalpur, Madhya Pradesh, found all three of them guilty on various counts by decision dated December 29, 2016, which was rendered there. While Raja and Rajesh Yadav were found guilty of offenses under Section 302 IPC read with Section 120B IPC, Section 364A read with Section 120B IPC, and Section 201 IPC, Om Prakash Yadav was found guilty under Section 364A read with Section 120B IPC.
- On the same day, sentences were handed down for the three of them. Om Prakash Yadav was given a life sentence and a two-month default sentence if he didn't pay a fine of 2,000 rupees.
- If Raja Yadav and Rajesh Yadav failed to jointly pay the fine sums of 1,000 rupees and 1,000 rupees, respectively, they were each sentenced to two months of default imprisonment and Raja Yadav was given a death sentence for the offenses under Sections 302 and 364A IPC. In addition, each of them received sentences of five years of hard labor and a $500 fine for the offense under Section 201 of the IPC, along with one month of detention without charge.
- All three prisoners filed an appeal with the High Court of Madhya Pradesh, feeling vindicated thereby. The three convicts are appealing this decision before this court through these appeals by special leave.
ISSUES RAISED
The issue raised was whether the accused can be held guilty when the evidences presented cannot prove the case beyond reasonable doubt?
JUDGEMENT ANALYSIS
- The court found that despite the numerous flaws and gaps in the prosecution's case, both the Trial Court and the High Court were not only willing to accept it at face value but also went so far as to sentence Rajesh Yadav and Raja Yadav to death and uphold that sentence.
- There were no good justifications offered as to why this instance was the "rarest of rare cases" and required such severe punishment. Instead, we believe that the case's glaring flaws and holes in the chain of circumstantial evidence call for the appellants to be exonerated and given the benefit of the doubt.
- It is evidently not proved to the level of proof necessary to declare them guilty beyond a reasonable doubt based solely on circumstantial evidence.
- We uphold the appeals and vacate the convictions and sentences of all three appellants on all charges based on the analysis mentioned above. If their continuing detention is not legally required in connection with another matter, they will be released immediately.
- They must reimburse any fine money they may have paid, if any, within eight weeks of today.
CONCLUSION
In a criminal case it is mandatory to prove the case beyond reasonable doubt. If there is any doubt in the mind of the judges then the accused cannot be made liable. In the given case also, the prosecution story does not appear to inspire confidence or is truthful and the prosecution has, thus, miserably failed to discharge its initial onus of establishing its case against the accused to and, thus, giving benefit of doubt to the accused Malkiat Singh, he was acquitted of the charges so framed against him.
