The Supreme Court has clarified that an investigation’s shortcomings do not automatically invalidate the prosecution’s case if other convincing and reliable evidence supports the guilt of the accused.
Case Background
In the case of R. Baiju v. The State of Kerala, the Court upheld the conviction of the accused, rejecting his claim that a faulty and politically influenced investigation should render the entire case void. The Court observed that despite issues with the investigation process, the presence of independent and credible evidence justifying conviction cannot be ignored.
“Even when the probity of investigation is suspect, the rest of the evidence must be scrutinised meticulously to ensure that criminal justice is not rendered a causality,” the Court stated, citing the precedent State of Karnataka v. K. Yarappa Reddy (1999).
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The appellant, referred to as Accused No. 6 (A6), was initially sentenced to death by the trial court for conspiracy and inciting others to kill. On appeal, the High Court altered his conviction to Section 304 Part II read with Section 120B IPC and imposed a 10-year rigorous imprisonment, along with 5 years under Section 450/120B IPC, plus fines.
A6 argued that he was falsely implicated due to political rivalry and that witness statements were changed later under judicial influence. However, the Supreme Court found that the motive was clearly established through prior incidents—an argument between A6 and the deceased over the forced purchase of coir mats and another clash at a local Ward Council Meeting.
“There is sufficient corroboration for the incident which happened in the afternoon and in the evening… which led to the attack on the family members of the deceased. The motive alleged hence stands established,” the Court said.
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Eyewitnesses, including the deceased’s family members (PWs 1 to 3), consistently described A6 as standing outside the house and inciting others to “kill them.” The Court dismissed the defense’s comparison of A6 with another accused (A5) who was acquitted, explaining that A6 had no valid reason to be present at the crime scene and played an active role in the attack.
“We cannot find the evidence against A5 and A6 to be identical. The culpability of A6… is quite evident; his presence at the scene of occurrence established by the ocular testimony,” the Court highlighted.
The Supreme Court also noted deliberate interference in the early stages of the investigation, likely to protect A6, who was an influential political figure. Despite the initial investigation omitting A6’s name, later statements under judicial supervision and the presence of multiple witnesses firmly established his involvement.
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Finally, the Court ruled that even if the initial investigation was biased, the body of credible evidence against A6 was overwhelming.
“The attack was carried out under his watchful eyes. Though the intention to kill may not be clear, the knowledge that the attack could cause death can be pinned down on A6.”
The appeal was dismissed, and the conviction and sentence were upheld.
Appearance:
For Petitioner(s) Mr. Nagamuthu S, Sr. Adv. (NP) Mr. Abhilash M.R., Adv. Mr. Sayooj Mohandas, Adv. Mr. Rajkumar, Adv. M/S. M R Law Associates, AOR
For Respondent(s) Mr. Nishe Rajen Shonker, AOR Mrs. Anu K Joy, Adv. Mr. Alim Anvar, Adv. Mr. Santhosh K, Adv.
