Conviction Based On Unproven 'Revenge Theory' & Incomplete Circumstantial Evidence Is Unsustainable: Rajasthan High Court Acquits Man in Murder Case

Rajasthan High Court Acquits Man in Murder Case, Cites Flawed Circumstantial Evidence and Unproven 'Revenge Theory'

Jodhpur, Rajasthan - The Rajasthan High Court has acquitted Sanjay Kumar, a man sentenced to life imprisonment for murder, ruling that a conviction cannot be sustained on a flawed investigation and an incomplete chain of circumstantial evidence. The division bench of Justice Manoj Kumar Garg and Justice Ravi Chirania overturned the 2016 trial court judgment, emphasizing that suspicion, however strong, cannot replace the need for proof beyond a reasonable doubt.

The court found "serious and material contradictions" in the prosecution's case, which was built entirely on circumstantial evidence and a motive of revenge that it failed to conclusively prove.

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Background of the Case

The prosecution's case originated from a complaint filed by Sanjeet Jha on April 20, 2015. He alleged that the appellant, Sanjay Kumar, deliberately ran over and killed Madan Jha with a pick-up van. The motive, as alleged, was long-standing enmity stemming from Sanjay's purported attempt to establish an illicit relationship with the deceased's wife, Ranju Jha (PW-7).

According to the complaint, Sanjay had threatened Ranju Jha on the evening of the incident, stating he would kill her husband. Hours later, Madan Jha was found dead on the road after being hit by a vehicle. Based on this, the Additional Sessions Judge No.2, Abu Road, convicted Sanjay Kumar under Section 302 of the Indian Penal Code (IPC) and sentenced him to life imprisonment.

Appellant's Arguments: A Case Riddled with Holes

Appearing for the appellant, Senior Advocate Dhirendra Singh argued that the entire prosecution case was based on a "self-designed story" without any direct evidence. Key arguments included:

• No Eyewitnesses: The prosecution's key witnesses, complainant Sanjeet Jha (PW-1) and the deceased's wife Ranju Jha (PW-7), did not witness the incident.
• Contradictory Testimonies: Ranju Jha claimed she was informed about the incident by a man named Parveez (PW-12), who supposedly saw Sanjay hit her husband. However, Parveez was declared a hostile witness after denying any knowledge of the incident or the people involved.
• Failure to Produce Key Informant: Sanjeet Jha testified that he was first alerted to the death by a reporter, Vikram Purohit. The prosecution never produced this reporter as a witness, leaving a critical gap in the chain of events.
• Weak Motive: The "revenge theory" was not supported by credible evidence. A prior police complaint (Exhibit-P/20) from 14 months before the incident did not mention the alleged attempt to form an illicit relationship, making it a weak basis for motive.

High Court's Scrutiny and Rationale

The High Court meticulously dissected the prosecution's evidence and found it wanting. The judgment highlighted that in a case resting on circumstantial evidence, the prosecution must establish a complete and unbroken chain of events that points exclusively to the guilt of the accused.

Pivotal Excerpts from the Judgment

The court noted the fatal contradictions in the prosecution's narrative:

“This Court while examining the statement of PW-12, Parveez, noted that this witness was declared hostile by the prosecution and he expressed complete ignorance about the incident... therefore, there is no specific evidence on record as to who informed the incident to PW-1 and PW-7 and who hit the deceased.”

The bench invoked the "panchsheel" or five golden principles for circumstantial evidence laid down by the Supreme Court in Sharad Birdhichand Sarda vs. State of Maharashtra (1984) . It concluded that the prosecution failed to meet this high standard.

“The learned trial court blindly relied upon the story of prosecution of alleged attempt by accused to make illicit relationship with PW-7 Ranju Jha, wife of the deceased, and accepted it as a revenge theory... After detailed examination of record, this Court note that there is no direct or indirect evidence available on record... which could lead to a definite conclusion that the alleged offence was committed by the accused-appellant.”

The court also observed that while forensic evidence suggested paint from the deceased's cycle was found on the pick-up van, this alone could not be the sole basis for a murder conviction in the absence of a complete chain of evidence proving who was driving the vehicle and with what intent.

Final Decision and Its Implications

Concluding that the prosecution "failed to prove its case beyond reasonable doubt," the High Court quashed and set aside the conviction and sentence passed by the trial court. Sanjay Kumar, who has been in jail, was ordered to be released immediately.

This judgment serves as a strong reminder of the judiciary's role in ensuring that convictions, especially for grave offenses like murder, are based on solid, unimpeachable evidence rather than presumptions, inconsistencies, and unproven motives.