Read Full Judgment: Chandan v. The State (Delhi Admn.)
In Criminal Appeal No. 788 of 2012, the Supreme Court of India upheld the conviction of the appellant, Chandan, under Section 302 of the Indian Penal Code (IPC). The appellant was convicted for the daylight murder of Rakesh, with a reliable eyewitness testifying against him. The incident occurred on May 28, 1993, around 8:15 pm, when the eyewitness, PW-2, saw the appellant stabbing the deceased multiple times with a knife after a scuffle between them. Despite immediate medical attention, Rakesh succumbed to his injuries at Hindu Rao Hospital. The post-mortem examination revealed multiple incised stab wounds on Rakesh’s body, indicating a brutal attack.
The prosecution’s case relied heavily on the testimony of PW-2, who witnessed the entire incident and provided a detailed account of the events leading to Rakesh’s death. The accused was apprehended on the same day near the crime scene, with a blood-stained knife in his possession. Forensic evidence confirmed that the recovered knife was used in the commission of the crime, with blood matching that of the deceased found on it. The swift arrest of the accused, coupled with the matching blood evidence, strengthened the prosecution’s case.
Although the defense raised doubts regarding the manner of knife recovery, the court deemed them inconsequential given the strong corroborative evidence, including the eyewitness testimony and forensic analysis. The absence of a clear motive for the crime did not undermine the credibility of the eyewitness, as established in previous legal precedents cited by the court. The principle reiterated in various cases emphasized that the lack of motive is irrelevant when there is direct evidence, such as reliable eyewitness testimony, establishing the crime.
Based on the comprehensive evaluation of the evidence presented, the court affirmed the decisions of both the Trial Court and the High Court, dismissing the appeal. The interim bail granted to the appellant was revoked, and he was directed to surrender before the Trial Court within four weeks to serve the remaining part of his sentence. The judgment highlighted the importance of eyewitness testimony in cases lacking a clear motive, reinforcing the legal principle that credible direct evidence outweighs the significance of motive in establishing guilt beyond a reasonable doubt.
