The Supreme Court of India ruled that while prior enmity between the accused and the victim can establish a possible motive, it also opens the possibility of false accusations. The bench of Justices BR Gavai and AG Masih overturned the conviction of an appellant in a 30-year-old murder case, granting him the benefit of the doubt.

The case revolved around the murder of a man named Guddu, with the prosecution asserting that the accused had killed him due to prior enmity. However, the Court found inconsistencies in the evidence, leading to the conclusion that the accused may have been falsely implicated.

The accused argued before the Court that even if the prosecution’s evidence was accepted at face value, it clearly showed that the incident arose from a quarrel. The deceased himself was armed with a knife, and during the altercation, the appellant picked up the knife and attacked him in self-defense.

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The appellant contended that there was no intention to commit murder, and thus, the case should not fall under Section 302 of the Indian Penal Code (IPC). Instead, he sought relief under Exception 4 of Section 300 IPC, which applies when an act is committed in the heat of the moment without premeditation.

The Supreme Court carefully analyzed the prosecution’s claims and found crucial gaps in the evidence. One of the key observations was the criminal history of the deceased, which played a significant role in the Court’s decision.

“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.”

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The Court emphasized that enmity is a double-edged sword—on one hand, it can establish motive, but on the other, it increases the likelihood of false accusations.

“It is a settled law that enmity is a double-edged weapon. On one hand, it provides motive; on the other hand, it 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 identified multiple contradictions and procedural lapses in the prosecution’s case that raised serious doubts about its credibility. These included:

1. The witnesses who carried the deceased to the hospital did not have bloodstains on their clothes.
2. The witnesses failed to inform the nearby police station or a police constable present just 50 steps away from the crime scene.
3. Discrepancies in witness testimonies regarding their presence at the scene.
4. The witnesses did not mention the accused’s name in the Medico-Legal Certificate (MLC), even though they claimed to have witnessed the incident.
5. A significant 45-day delay in recording crucial witness statements, despite their availability.

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These inconsistencies collectively weakened the prosecution’s case and cast serious doubt on the appellant’s alleged guilt.

Considering the above factors, the Supreme Court allowed the appeal and acquitted the accused of all charges. The judgment reiterates the principle that while prior enmity can be a basis for motive, it cannot be the sole determinant of guilt without strong supporting evidence.

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

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