Introduction:

The Supreme Court of India, in its recent judgment in Aslam alias Imran v. The State of Madhya Pradesh, set aside a conviction in a three-decade-old murder case, ruling that the possibility of false implication due to prior enmity cannot be ignored. A bench comprising Justices B.R. Gavai and A.G. Masih observed that while enmity provides motive, it equally raises the risk of wrongful accusations. The appellant was convicted of murder under Section 302 of the Indian Penal Code (IPC) but contended that the prosecution’s evidence was riddled with inconsistencies and delays. The Court, upon reviewing the evidence, granted the appellant the benefit of the doubt and acquitted him.

Arguments of Both Sides:

The appellant argued that even if the prosecution’s version was accepted at face value, it only showed a quarrel between him and the deceased. He claimed that the deceased had a knife, and in the heat of the altercation, he picked it up and assaulted him. The defense argued that this case, at best, fell under Exception 4 of Section 300 IPC (culpable homicide not amounting to murder) and did not warrant a conviction under Section 302 IPC. Furthermore, the appellant contended that the deceased had a history of criminal activities, making it plausible that he was falsely implicated. On the other hand, the prosecution maintained that the appellant intentionally murdered the deceased due to prior enmity. It argued that the appellant’s motive was clear and supported by witness testimonies. However, contradictions in the statements of witnesses, the unexplained delay in recording their statements, and the lack of bloodstains on those who allegedly carried the deceased to the hospital weakened the prosecution’s case.

Court’s Judgment:

The Supreme Court scrutinized the prosecution’s evidence and found multiple factors casting doubt on the veracity of the witnesses. It noted that the deceased was a history-sheeter with criminal cases, including an attempt to murder. Given this background, the Court emphasized that enmity is a “double-edged weapon”—it can provide a motive, but it also makes false accusations plausible. The Court further pointed out inconsistencies such as the absence of bloodstains on those who allegedly transported the deceased, contradictions in the witnesses’ presence at the crime scene, and an unexplained 45-day delay in recording key testimonies. Observing these lapses, the Court ruled that the benefit of the doubt must go to the appellant and acquitted him of all charges.