Case Analysis: Sabitri Samantaray V. State Of Odisha (2022 LiveLaw (SC) 503)

• Bench:
  • Hon'ble Chief Justice N.V. Ramana
  • Hon'ble Justice Krishna Murari
  • Hon'ble Justice Hima Kohli
• Jurisdiction: Supreme Court of India, Criminal Appellate Jurisdiction
• Citation: 2022 LiveLaw (SC) 503
• Date of Judgment: 20th May 2022
• Criminal Appeal Nos: 988 of 2017 and 860 of 2022 (Arising out of S.L.P (CRL.) No. 3881 of 2017)
• Parties:
  • Appellants: Sabitri Samantaray and Bidyadhar Praharaj
  • Respondents: State of Odisha
• Advocates:
  • For Appellants: Mr. Debesh Panda, AOR
  • For Respondents:
    • Ms. Anindita Pujari, AOR
    • Mr. Siddhartha Srivastava, Adv.
    • Mr. Azad Bansala, Adv.
    • Ms. Prakriti Rastogi, Adv.
    • Mr. Suvendu Suvasis Dash, AOR
    • Ms. Swati Vaibhav, Adv.

Background:
The appellants, Sabitri Samantaray and Bidyadhar Praharaj, along with their daughter, were accused of murdering Sanjay Rana, who had a relationship with their daughter. Initially charged under Sections 302, 201 read with Section 34 of the Indian Penal Code (IPC), the appellants were sentenced to life imprisonment by the Sessions Court. The High Court later acquitted the daughter and modified the appellants' conviction to Section 304(II) IPC, sentencing them to five years of rigorous imprisonment.

Facts of the case:

• The incident occurred on 21.07.2008 when the landlord, Mayadhar Mohapana, heard cries and saw an unknown person assaulting the appellants with a "Kata". The person was found dead inside the appellants' house, initially suspected of suicide.
• The deceased was identified as Sanjay Rana, who had a relationship with the appellants' daughter.
• Post-mortem revealed the death was homicidal, caused by compression on the neck and assault with acid and blunt objects.
• The appellants claimed the deceased entered their house forcibly, assaulted them, and threatened to kill them unless they handed over money and valuables.

Issues

• Whether the prosecution successfully established the guilt of the appellants beyond reasonable doubt.
• The applicability of Section 106 of the Indian Evidence Act, 1872 in the context of circumstantial evidence.
• The adequacy of evidence presented to convict the appellants under Section 304 (II) IPC.

Contentions of the Appellants

• The reliance on Section 106 of the Evidence Act was misplaced in the absence of clear evidence.
• The prosecution failed to prove the case beyond reasonable doubt.
• The High Court erred in convicting the appellants based on circumstantial evidence without any eyewitness testimony.
• Answers given under Section 313 CrPC were inadmissible and should not have been relied upon.
• No prima facie finding indicated the appellants' participation in the deceased's death.

Contentions of the Respondents

• The High Court rightly relied on credible evidence and the relationship between the deceased and the appellants.
• Section 106 of the Evidence Act was correctly applied as the appellants were the only ones present at the scene of the crime.
• The prosecution successfully established the chain of events beyond reasonable doubt, indicating the appellants' guilt.

Judgment:
The Supreme Court upheld the High Court's conviction of the appellants under Section 304 (II) IPC. The Court emphasized that Section 106 of the Evidence Act does not relieve the prosecution of its burden of proof but applies when the prosecution establishes a chain of events leading to a reasonable inference against the accused. The Court found that the prosecution had successfully established the chain of events and the appellants' responses to incriminating questions were inadequate, serving as an additional link in the chain of evidence.

Analysis:

• Application of Section 106 of the Evidence Act: The Court noted that Section 106 requires the accused to explain facts within their special knowledge. In this case, the appellants' inability to provide a plausible explanation for the events, coupled with their inconsistent responses, reinforced the prosecution's case.
   
• Evidence of Circumstantial Nature: The Court relied on the testimony of PW 9 (the landlord) and the forensic evidence which established that the appellants were the only ones present in the house at the time of the deceased's death. The medical evidence corroborated the cause of death as homicidal due to strangulation and assault with acid.
   
• Consistency and Credibility of Witnesses: The Court found that the statements of the prosecution witnesses were consistent and credible, rejecting the appellants' defense of an unknown assailant's forced entry and subsequent assault on them.

Conclusion:
The Supreme Court's judgment underscores the nuanced application of Section 106 of the Indian Evidence Act in cases reliant on circumstantial evidence. By affirming the High Court's conviction under Section 304 (II) IPC, the Court reiterated the importance of a consistent and credible chain of events established by the prosecution, and the role of the accused's explanations in reinforcing the prosecution's case. This case serves as a significant reference for the interpretation and application of evidentiary principles in criminal jurisprudence.