Ratnu Yadav vs. State of Chhattisgarh [July 09, 2024]
Citation: [2024] 7 S.C.R. 466; 2024 INSC 487; Criminal Appeal No. 1635 of 2018
Background and Facts
Ratnu Yadav was convicted by the Sessions Court under Section 302 of the Indian Penal Code (IPC) for the alleged murder of his stepmother, Hemwati Bai, following a land dispute. The prosecution claimed that Yadav assaulted her, dragged her by the hair to a village pond, and drowned her. The conviction was based primarily on an extra-judicial confession to the village officer (PW-1) and the testimony of the deceased’s brother (PW-5), who allegedly witnessed the incident. The High Court upheld the conviction and life sentence, leading to an appeal before the Supreme Court.
Key Issues
Whether the extra-judicial confession and “last seen” testimony were reliable and sufficient to sustain the conviction.
Whether the prosecution proved the guilt of the accused beyond reasonable doubt, especially in the absence of direct evidence and material witnesses.
The evidentiary value of the confession and procedural compliance with the Evidence Act and CrPC.
Supreme Court’s Analysis and Findings
Extra-Judicial Confession: The Supreme Court found the extra-judicial confession unreliable. It noted that such confessions are inherently weak evidence and must be corroborated by other credible evidence. The Court observed that the appellant did not have a close relationship with PW-1, making it unlikely he would confess to her. Furthermore, PW-1’s testimony was inconsistent between examination-in-chief and cross-examination, undermining its credibility.
Last Seen Evidence: The testimony of PW-5, who claimed to have seen the appellant dragging the deceased, was not corroborated by physical evidence. The Court highlighted that the site map showed a considerable distance between the house and the pond, and the absence of injury marks on the deceased’s body contradicted the prosecution’s version. If the deceased had been dragged by her hair, some injuries would be expected.
Procedural Lapses: The Court found that material witnesses, including a neighbor who allegedly intervened, were not examined. The postmortem report confirmed drowning but did not conclusively establish homicidal death. There was also no correlation established between the pond water and the water found in the deceased’s lungs.
Legal Principles: The Court reiterated that extra-judicial confessions require corroboration and that conviction cannot be based on weak or uncorroborated evidence. The failure to confront witnesses with their prior statements under Section 145 of the Evidence Act further weakened the prosecution’s case.
Conclusion and Significance
The Supreme Court set aside the judgments of the Sessions Court and High Court, acquitting Ratnu Yadav and ordering his immediate release unless required in another case.
The judgment emphasizes the need for rigorous scrutiny of extra-judicial confessions and the importance of corroborative evidence in criminal trials.
It reinforces the principle that the prosecution must prove guilt beyond reasonable doubt, and procedural lapses or weak evidence cannot sustain a conviction for murder.
In summary: The Supreme Court acquitted Ratnu Yadav, holding that the prosecution failed to prove his guilt beyond reasonable doubt due to unreliable extra-judicial confession, lack of corroborative evidence, and procedural deficiencies.
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