Indian Penal Code, 1860 – Sections 394, 397 – Robbery – Conviction set aside – Prosecution Evidence – Disclosure Statement – The Supreme Court adjudicated on a criminal appeal arising from a judgment of the Madhya Pradesh High Court affirming the appellant’s conviction under Sections 394 read with Section 397 of the Indian Penal Code, 1860 (IPC). The appellant, Hansraj, was accused of snatching jewelry from the complainant and convicted by the trial court based on the recovery of the stolen articles. However, the Supreme Court analyzed the evidence and found serious lapses in the prosecution’s case.
The prosecution’s case relied heavily on a disclosure statement allegedly made by the accused, leading to the recovery of the stolen jewelry. However, the Investigating Officer failed to properly prove the disclosure memo as required by law. Moreover, the recovery process lacked procedural adherence, with no evidence of proper sealing or secure storage of the recovered articles. Additionally, the complainant’s identification of the recovered items was influenced by police officials, casting doubt on its reliability.
Considering these deficiencies, the Supreme Court concluded that the prosecution failed to establish the guilt of the appellant beyond reasonable doubt. As a result, the Court allowed the appeal, quashing the judgments of both the trial court and the High Court. The appellant was acquitted of all charges. (Para 14, 16)
SUPREME COURT OF INDIA
2024 STPL(Web) 271 SC = 2024 INSC 318
Hansraj Vs. State Of M.P.
Criminal Appeal No(S). OF 2024 (Arising out of SLP (Crl.) No(s). 4626 of 2024)-Decided on 19-04-2024
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