The Supreme Court has recently reiterated a crucial principle in criminal jurisprudence: doubtful conduct alone is insufficient to convict an accused. There must be other credible evidence to prove the accused's involvement in a crime. This ruling emphasizes the importance of solid evidence and the dangers of relying solely on suspicion, even when the accused's behavior appears incriminating.
In a recent case, the Supreme Court overturned a lower court's conviction in a murder case, where the conviction was primarily based on the accused's conduct. The trial court and High Court had relied on the fact that the accused had allegedly approached the police and lodged a First Information Report (FIR) admitting to the offense. However, the Supreme Court bench, comprising Justices J.B. Pardiwala and R. Mahadevan, clarified that an FIR of a confessional nature is inadmissible as evidence against the accused. It can only be used to show that the accused made a statement soon after the offense, identifying them as the report's maker, which is admissible as evidence of their conduct. Additionally, any information provided by the accused that leads to the discovery of a fact can be admitted. The court noted that a non-confessional FIR is admissible against the accused as an admission.
The Supreme Court cautioned that while the conduct of an accused is relevant under Section 8 of the Indian Evidence Act, it cannot be the sole basis for conviction, especially in serious charges like murder. The conduct of the accused is just one circumstance that the court can consider alongside other direct or circumstantial evidence. To justify a conviction, there must be cogent and credible supporting evidence.
This ruling aligns with the fundamental principle of criminal law that an accused is presumed innocent until proven guilty beyond a reasonable doubt. The prosecution bears the burden of proving the guilt of the accused, and this burden requires presenting sufficient evidence to overcome the presumption of innocence. Doubtful conduct, without more, does not meet this high standard of proof. The prosecution must prove beyond a reasonable doubt that the accused committed the crime. Direct evidence, such as eyewitness testimony, physical evidence, and forensic evidence, can be used to prove a defendant guilty beyond a reasonable doubt.
The Supreme Court's decision serves as a reminder to lower courts to avoid the pitfalls of convicting individuals based on mere suspicion or questionable behavior. It reinforces the need for a thorough investigation, the collection of reliable evidence, and a fair trial where the prosecution meets its burden of proof. It also underscores the importance of due process, ensuring that an individual's rights are protected throughout the legal proceedings. Relying on weak or circumstantial evidence can erode public trust in the justice system.
This judgment also highlights the importance of distinguishing between the relevance of conduct as a piece of evidence and its sufficiency to establish guilt. While suspicious behavior can be a relevant fact that prompts further investigation, it cannot replace the need for concrete evidence that links the accused to the crime. The courts must consider the totality of the evidence on record and ensure that a conviction is based on firm legal grounds, not just a perception of guilt. The role of the jury is to consider the direct evidence and decide on a verdict. A defense attorney must prove that reasonable doubt exists.
