Judges Cannot Rely On Moral Convictions To Secure Conviction In Absence Of Legal Evidence: Supreme Court
The Supreme Court recently acquitted six accused, including Dr. Renuka Prasad, Director of the Academy of Liberal Education, in the 2011 murder of Prof. A.S. Ramakrishna, setting aside the Karnataka High Court’s 2023 decision which had reversed their acquittal.
The Bench of Justice Sudhanshu Dhulia and Justice K. Vinod Chandran strongly criticised the High Court for convicting the accused in the absence of any legal evidence, observing that Courts must not “tread the path of righteousness” and convict merely on moral conviction when evidence is lacking.
“With a heavy heart for the unsolved crime, but with absolutely no misgivings on the issue of lack of evidence, we acquit the accused,” the Court said, reinstating the trial court’s order that had initially acquitted the accused.
Senior Advocates Sidharth Luthra and Ratnakar Dash represented the accused, while Additional Advocate General (AAG) Aman Panwar appeared for the State of Karnataka.
Facts of the Case
Prof. Ramakrishna, Administrative Officer of KVG Medical College, was brutally hacked to death during a morning walk near Ambatedka in Dakshina Kannada district on April 28, 2011.
The prosecution alleged that Renuka Prasad had ordered the murder due to resentment over his father’s division of responsibilities within the family-run education institutions. It was claimed that Prasad believed Ramakrishna had influenced this division and was managing the college on behalf of Prasad’s elder brother.
Court's Observations
The Court noted that the entire prosecution case collapsed during trial, with 71 of 87 witnesses; including key eyewitnesses, turning hostile. Even the deceased's son, who allegedly witnessed the killing, failed to identify the attackers.
As a result, the case rested solely on official and police witnesses, which the Court found insufficient to sustain conviction.
“We find absolutely no reason to sustain the conviction entered by the High Court, reversing the order of acquittal,” the Bench stated.
The Court took exception to the High Court's approach, stating that a conviction based purely on the prosecution’s narrative without supporting legal evidence is a grave error.
“The High Court has egregiously erred in convicting the accused on the evidence led and has jumped into presumptions and assumptions based on the story scripted by the prosecution without any legal evidence being available,” the Bench observed.
The Bench remarked, "Truth is always a chimera and the illusion surrounding it can only be removed by valid evidence led, either direct or indirect, and in the event of it being circumstantial, providing a chain of circumstances with connecting links leading to the conclusion of the guilt of the accused and only the guilt of the accused, without leaving any reasonable doubt for any hypothesis of innocence."
"We can only accede to and share the consternation of the Division Bench of the High Court, which borders on desperation, due to the futility of the entire exercise. That is an occupational hazard, every judge should learn to live with, which cannot be a motivation to tread the path of righteousness and convict those accused somehow, even when there is a total absence of legal evidence; to enter into a purely moral conviction, total anathema to criminal jurisprudence," it added.
Referring to the larger implications, the Court said, “Prevaricating witnesses, turning hostile in court, and overzealous investigations done in total ignorance of basic tenets of criminal law often reduce prosecution to a mockery.”
On the High Court’s apparent desperation to deliver justice in the face of a gruesome crime, the Bench warned that such motivation cannot justify convicting individuals in the absence of evidence. “That is an occupational hazard every judge should learn to live with,” the Court said, adding that moral convictions have no place in criminal jurisprudence.
Accordingly, the Court allowed the Criminal Appeals.
Case Title: Renuka Prasad v. The State [Crl. A. Nos. 3189-90 of 2023 etc.]