'Prior Enmity Can Indicate Motive But Also Raise Possibility Of False Accusation' : Supreme Court Acquits Man In 30-Year-Old Murder Case

The Supreme Court  (March 27) observed that when a criminal act is committed based on prior enmity with the victim, then the possibility of false accusations cannot be ruled out. Though hostility between parties can establish a motive for a crime, it also raises the possibility of false accusations driven by personal grudges.

Holding so, a bench of Justices BR Gavai and AG Masih overturned a man's conviction in a 30-year-old murder case, where the prosecution claimed the appellant-accused murdered the deceased due to prior enmity. While the prosecution presented evidence of motive, the nature of the evidence raised doubts about possible false implications. Considering this uncertainty, the Court granted the appellant the benefit of the doubt and acquitted him.

The Appellant argued before the Supreme Court that even if the evidence of the prosecution witnesses is taken at its face value, it would clearly reveal that there was a quarrel between the appellant and the deceased. It was the deceased who had a knife and as a result of the quarrel, the appellant picked up the knife of the deceased and assaulted him. He therefore submits that it is thus clear that the prosecution has failed to prove that the appellant-accused had any intention of causing the death of the deceased. He submits that, in any case, the appellant would be entitled to benefit of Exception 4 of Section 300 of IPC and the case would not fall under the category of Section 302 of IPC.

Instead of examining the case as culpable homicide not amounting to murder, the Court reviewed the evidence and noted the deceased's history of criminal activity and prior enmity with the appellant. This raised the possibility of false implication, as enmity can both establish motive and suggest wrongful accusation.

“It has come in the evidence on record that the deceased Guddu was a history-sheeter and was facing many criminal cases including a case for attempt to murder. It has also come in the evidence of prosecution witnesses that there was a previous enmity between the deceased and the appellant.”, the court noted

“It is a settled law that enmity is a double-edged weapon. On one hand, it provides motive, on the other hand it also does not rule out the possibility of false implication. From the nature of the evidence placed on record by the prosecution, the possibility of the present appellant being falsely implicated on account of previous enmity cannot be ruled out. In our opinion, therefore, the appellant is entitled to benefit of doubt”, the court added.

Further, the Court cited other factors which cast doubt over the prosecution's case such as contradictions in witness statements and an unexplained 45-day delay in recording key witness testimonies, which weakened the prosecution's case.

“The following factors cast a serious doubt on the veracity of the prosecution witnesses:

(i) The witnesses who were carrying the deceased Guddu to the hospital not having bloodstains on their clothes;

(ii) The witnesses not informing either the Police Station or the police constable who was standing at a distance of about 50 steps from the place of incident;

(iii) The contradictions in the evidence of witnesses with regard to presence of each other at the place of incident;

(iv) The witnesses not informing the cause of death of the deceased Guddu in the MLC papers, though according to them they were aware about the person who had inflicted the injury on the deceased; and

(v) Recording of the statement of the witnesses after a long gap after the date of incident when the said witnesses were very much available.”

Accordingly, the Court allowed the appeal and acquitted the Appellant of all the charges leveled against him.

Case Title: ASLAM ALIAS IMRAN VERSUS THE STATE OF MADHYA PRADESH

Citation : 2025 LiveLaw (SC) 365

Click here to read/download the judgment

Appearances:

For Petitioner(s) : Mr. Snajay R. Hegde, Sr. Adv. Mr. Prathvi Raj Chauhan, AOR Mr. Venkatesh Rajput, Adv. Mr. Nepal Singh, Adv. Mr. Varun Kumar, Adv. Mr. Meghraj Singh, Adv.

For Respondent(s) : Ms. Mrinal Gopal Elker