Manikandan vs. State by the Inspector of Police [April 5, 2024]
Background
Manikandan and co-accused were convicted by the Sessions Court and the High Court for murder under Section 302 read with Section 34 of the Indian Penal Code. The conviction was primarily based on the testimonies of prosecution witnesses who were closely related to the deceased. The appellants challenged their conviction before the Supreme Court, alleging that the witnesses had been tutored by the police and that there was a gross misuse of police power, undermining the integrity of the judicial process.
Key Legal Issues
Whether the conviction could stand when prosecution witnesses were found to be tutored by the police.
Whether the absence of independent witnesses and the presence of substantial doubt in the prosecution’s case warranted acquittal.
Supreme Court’s Analysis
The Supreme Court scrutinized the manner in which the prosecution witnesses (PW-1 to PW-5) were handled. It was revealed that, a day before their court testimony, these witnesses were called to the police station and instructed on how to depose, constituting blatant tutoring and a serious abuse of police power. The Court expressed astonishment that such a crucial violation was overlooked by the trial courts.
The Court further noted:
The prosecution’s case rested entirely on interested witnesses whose testimonies were influenced and therefore unreliable.
The defense’s claim that the accused were elsewhere at the time of the incident remained unchallenged, as the prosecution failed to present any independent witnesses.
The manipulation of witnesses by the police cast serious doubt on the genuineness of the prosecution’s case and amounted to a gross interference with the judicial process.
Judgment
Given these findings, the Supreme Court concluded that the benefit of doubt must be extended to the accused, especially since they had already suffered over a decade of incarceration before being released on bail pending appeal. The Court set aside the judgments and orders of the trial court and the High Court, acquitting the appellants of all charges.
Significance
This judgment sets a precedent on the impermissibility of police tutoring of witnesses and the necessity for courts to scrutinize the reliability of such evidence. It reinforces the principle that the prosecution must prove its case beyond reasonable doubt, and any manipulation or abuse of process by law enforcement will vitiate the prosecution’s case.
Citation:
Manikandan vs. State by the Inspector of Police, Supreme Court of India, Criminal Appeal No. 1609 of 2011, decided on April 5, 2024; 2024 INSC 272.
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