Introduction

This appeal arose from the conviction of Ranjeet Singh under Section 302 IPC for the alleged murder of Devnath/Deonath on 15 January 2010 in Madanpur forest, Chhattisgarh. The Trial Court sentenced him to life imprisonment, and the Chhattisgarh High Court affirmed the decision. On appeal, the Supreme Court scrutinized the reliability of the prosecution’s evidence, especially the delayed testimonies of minor eyewitnesses, and set aside the conviction.

Facts of the Case

1. Incident (15 January 2010): Devnath went to the forest to collect firewood. Later, his son Vikas Kumar (PW-1) found him dead with head injuries near a blood-stained stone.

2. FIR Registration: The FIR was lodged the same day by Vikas Kumar. It did not name any accused or mention eyewitnesses—only that “someone” killed the deceased.

3. Investigation: Ranjeet Singh, the appellant, accompanied PW-1 and PW-2 to lodge the FIR. Later, it was alleged he absconded after a sniffer dog traced the blood-stained stone to his house.

4. Eyewitness Statements: Nine days later, three minor girls—Anita (PW-13), Meena (PW-14), and Lali (PW-15)—claimed to have seen the murder. However, their testimony was doubted because of:

   • Close family ties with other key witnesses,

   • Their initial silence, and

   • Contradictory accounts about whether they were even in the forest that day.

5. Motive: The prosecution cited minor quarrels 2–3 months before the incident as the motive.

Issue

Whether the conviction of Ranjeet Singh under Section 302 IPC was sustainable given:

• The absence of direct evidence in the FIR,

• The delayed and doubtful testimonies of alleged eyewitnesses,

• Weak proof of motive, and

• Inconsistent claims of abscondence.

Judgment

1. Unreliable Eyewitnesses: The Court rejected the testimony of the three minors, finding their accounts doubtful due to delay, family influence, and contradictions.

2. Defective FIR: The FIR did not name any accused or mention eyewitnesses, weakening the prosecution’s case.

3. Weak Motive & Abscondence: Minor quarrels months before were insufficient to establish motive. The alleged abscondence was inconsistent and unproven.

4. Failure of Prosecution: The prosecution failed to prove guilt beyond reasonable doubt. Conviction based on circumstantial and doubtful evidence was unsustainable.

5. Final Order: The Supreme Court set aside the conviction and life sentence, acquitting Ranjeet Singh. He was ordered to be released immediately unless required in another case.

Conclusion

The Supreme Court reaffirmed the principle that conviction must rest on clear, consistent, and credible evidence. Mere suspicion, delayed testimonies, or weak circumstantial proof cannot justify upholding a conviction under Section 302 IPC. The judgment highlights the Court’s cautious approach in safeguarding the rights of the accused where prosecution evidence is unreliable.