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Smart Summary

Factual and Procedural Background

On the night of 9 May 1923 the house of Ram Sarup and Murli (alias Murlidhar) in Fakhanpur was attacked by a gang of dacoits. The gang captured Ram Sarup and Murli, compelled them to reveal the location of money and valuables, rifled an iron safe containing cash and ornaments, plundered the house, and set fire to straw in order to see. They used two lanterns and were well armed with guns and pistols. Three villagers were killed outright, a fourth later died of wounds, and two others were permanently crippled; medical evidence attributed injuries to gunshot wounds. The gang also plundered a neighbouring house and left the village around 1–2 a.m.

Investigations involved special police officers. Information was obtained from local persons, including Sheoraj Singh and a Kanungo, leading to the arrest of several accused at various dates in 1923. One individual, Sadua, was arrested on 16 July, made a confession recorded under section 164 of the Code of Criminal Procedure on 2 October, and became an approver. Jamna Das made a confession (date not specified here) and named accomplices. The accused were tried before the Additional Sessions Judge of Moradabad; eighteen men were convicted under section 396 of the Indian Penal Code. Three (Abdul Wahab, alias Habbu Khan; Muhammad Saved Khan; Jamna Das) were sentenced to death; the remainder received sentences of transportation for life. These persons appealed, and the present opinion addresses those appeals.

Legal Issues Presented

  1. Whether the confession and approver's statement (Sadua) could be relied upon and what weight should be attached to them, given the time elapsed and the circumstances of their recording (including recording under section 164 CrPC).
  2. Whether identification parades conducted in Haldwani jail, including the use of outsiders in the line, were lawful and whether the resulting identifications could be admitted and relied upon at trial.
  3. What is the proper method for proving prior identifications made before a Magistrate or at a jail when a witness is unable to identify the accused in open court (i.e., admissibility and method of proving jail or pretrial identifications).
  4. Whether convictions could lawfully rest on the uncorroborated testimony of an accomplice, and what the correct legal position is regarding corroboration of accomplice evidence.

Arguments of the Parties

Arguments Challenging the Confession and Approver's Evidence

  • It was argued that the value of Sadua's confession (recorded under section 164 CrPC) should be discounted because of the time which elapsed before it was made.

Arguments Challenging the Identification Procedure

  • The parade in Haldwani jail was criticized because outsiders were brought and placed in the line with the accused, making the procedure unusual and open to criticism.

Other or Implied Defence Contentions

  • Some accused were unable to identify persons in the Sessions Court whom they had identified earlier at the jail, which raised issues about the admissibility and sufficiency of the earlier identifications as evidence at trial.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Nagma v. Emperor That a Magistrate's evidence that a witness identified an accused in his presence is, in substance, hearsay and cannot be treated as direct evidence in court unless admissible under proper provisions (i.e., cannot substitute for the witness's in-court oath). The court relied on this authority to hold that the Sessions Judge erred in treating certain jail identifications (as testified to by the Magistrate) as direct evidence when the identifying witness could not identify the accused in court; such testimony, without proper procedural linkage, amounts to hearsay.
Nagina v. Emperor Demonstrates that where a witness identified an accused before the committing Magistrate but cannot do so before the Judge, the witness's prior statement can be brought on the record under section 288 CrPC. The court cited this case as the correct course where the prior Magistrate identification exists and the witness cannot identify at trial; it explained that section 288 CrPC was the mechanism adopted in Nagina.
Mahant Narain Das v. The Crown Sets out the correct law relating to conviction based on accomplice testimony and the need for proper treatment of such evidence (contrasting with an incorrect view that repeats section 133 Evidence Act literally). The court referred to this authority to correct the Sessions Judge's misstatement that a man cannot be convicted on the uncorroborated testimony of an accomplice as if that were restating section 133 of the Evidence Act; the court observed the learned Judge should consult Mahant Narain Das for the correct principle.

Court's Reasoning and Analysis

The court proceeded by examining the principal categories of evidence relied upon at trial: identifications made at the Haldwani jail, the approver's (Sadua's) statement and conduct, and the confession of Jamna Das.

On the approver (Sadua) and his confession: although it was argued that the value of Sadua's confession should be discounted because of the delay before it was recorded, the court found no cross-examination or other material to suggest that the confession was police-inspired or that materials had been supplied by police. Sadua adhered to his confession, was made an approver, and maintained consistency under cross-examination. His statement was strongly corroborated: he conducted the Magistrate over the scene and route of the dacoity; he produced a kathla he said was part of his share of the plunder which was satisfactorily identified; and the Magistrate's evidence confirmed that Sadua accurately pointed out occurrences in a manner consistent with both his statement and eye-witness testimony. The court concluded that the approver's statement was reliable and "a valuable piece of evidence."

On the jail identification parade: the court acknowledged the parade procedure at Haldwani jail was unusual because outsiders were brought and placed in the line with the accused owing to scarcity of under-trial prisoners. The court accepted the prosecution explanation that circumstances left no other practical course and noted that the Magistrate who conducted the parade took every possible precaution to prevent unfairness (witnesses were strangers to Haldwani and kept under the Magistrate's eye before the parade). Consequently, the court found the parade itself acceptable given the peculiar facts and precautions.

On the legal character of jail identifications when witnesses cannot identify at trial: the court identified an error in the Sessions Judge's treatment of certain identifications. If a witness identifies an accused before a Magistrate or at a jail but cannot identify the accused in open court, the mere testimony of the Magistrate that the witness identified a particular accused in his presence is, in substance, hearsay and cannot be treated as direct evidence. The court relied on Nagma v. Emperor to explain that such Magistrate testimony amounts to: "The witness said in my presence that a particular accused whom he pointed out took part in the dacoity," and is not an on-oath court statement by the witness.

The court set out two lawful routes to make prior identifications admissible: (1) The prior statement made before the committing Magistrate may be placed on the record under section 288 CrPC (as in Nagina v. Emperor) when the witness previously identified the accused before the Magistrate; (2) At trial the witness may be asked to state that he identified certain persons at the jail and that those persons were the ones he saw taking part in the crime, and then, under section 9 of the Evidence Act, other evidence (best being the Magistrate who conducted the identification) may be used to establish the identity of the persons so identified. The court observed that only Tulshi Gir among the witnesses who had failed to pick out persons in the Sessions Court fulfilled these conditions by deposing that he recognized the persons again at the identification before the tahsildar at Haldwani jail.

The court noted that although the Sessions Judge had erred in treating some jail identifications as direct evidence without linking them to in-court testimony or using statutory provisions, in the present case the error did not prejudice the convicted accused because there was sufficient additional evidence (including other reliable identifications and the approver's corroborated statement) against each accused affected by that error.

On the question of conviction based on accomplice testimony, the court criticized the Sessions Judge's remark that "a man cannot be legally convicted on the uncorroborated testimony of an accomplice" as an incorrect restatement of section 133 of the Evidence Act. The court directed the judge to Mahant Narain Das v. The Crown and other rulings for the correct exposition of the law regarding accomplice evidence.

Holding and Implications

Holding: The court ordered as follows (final order reproduced from the opinion):

  • For the three accused sentenced to death — Abdul Wahab, alias Habbu Khan, Muhammad Saved Khan, and Jamna Das — the appeals were dismissed and the sentences of death were confirmed; the court directed that these be carried out according to law.
  • For the remaining convicted persons — Ghuima Khan, Shabrati, Abdul Rahim Khan (alias Abdul), Prem, Sahib Singh, Ganga Ram, Alijan (son of Chheda Khan), Alijan (son of Ahmad Bakhsh), Jairaj, Lala (alias Tjalla), Jhabba, Behari, Nur Bakhsh (alias Nuri), Umrao and Baljit — the appeals were dismissed and the sentences of transportation for life were confirmed.
  • The further sentence of forfeiture imposed under section 92 of the Indian Penal Code was set aside because that section had been repealed by Act No. XVI of 1921.

Direct implications: Appeals dismissed and convictions upheld. The direct consequence is that the convictions and the principal sentences (death or transportation for life) as specified above remain in force, except that the ancillary forfeiture sentence under the now-repealed section 92 IPC was set aside. The opinion did not purport to lay down new legal precedent beyond applying and clarifying existing authorities and statutory provisions; it corrected the Sessions Judge's approach to certain evidentiary matters and relied on existing appellate authorities for the correct legal principles.

    Emperor v. Abdul Wahab And Others

    Daniels and Neave, JJ.:— Eighteen men have been convicted by the Additional Sessions Judge of Moradabad under Bection 396 of the Indian Penal Code. Three of them, Abdul Wahab, alias Habbu Khan, Muhammad Saved Khan and Jamna Das have been sentenced to death. The rest have been sentenced to transportation for life. They all appeal.

    On the night of the 9th of May, 1923, between 10 and 11 p.m the house belonging to Ram Sarup and Murli, alias Murlidhar, Bishnois, in the village of Fakhanpur was plundered by ducats. The gang found Murli and Ram Sarup sleeping just outside their house, and capturing them, made them lead them into the house and show where the money and valuables were kept. The gang first rifled an iron safe containing cash and ornaments of considerable value and then went on to plunder the house. They set fire to a quantity of straw in order to see what they were doing and also used two lanterns, one of which they had brought with them while the other they found hanging up in front of the house.

    The noise and flames aroused the village and three parties of villagers attempted a rescue, approaching the house from the east, the west and the south sides. Ram Sarup and Murli succeeded in making their escape in the confusion caused among the dacoits by the necessity to repel these attacks, though not till after Murli had been roughly handled on account of his refusal to disclose the hiding place of the rest of his money.

    The dacoits were well armed with guns and pistols which they used freely. Three villagers were killed outright and a fourth succumbed later to his wounds. Two others have been crippled for life. The medical evidence proves that all the injuries were caused by gunshots.

    The dacoits also visited and plundered the house of Nirmal, ten paces away, and finally left the village at 1 or 2 a.m

    The dacoits pretended to be Bhantus and Mr. Young, the Superintendent in charge of the special police employed in hunting the Bhantu gang which at the time was terrorizing the Tarai and neighbouring districts, took up the case. He deputed Bai Bahadur Tirath Singh, Deputy Superintendent of Police, to make inquiries. That officer, learning that the reason, for the selection of Ram Sarup as the victim of the dacoity was possibly the: extravagance with which he had recently celebrated the marriage of his daughter and the consequent reputation for wealth which he had acquired among his caste-fellows, asked sheoraj Singh, a Girdawar Kammgo, who is a Bishnoi by caste, to see what he could learn from Bishnois in the neighbourhood. At Surajnagar this officer heard that a quarrel had taken place between two men named Jamna Das and Jiraj over the division of the spoils taken in the Fakhanpur dacoity. Jamna Das is his connection by marriage, and by pretending to sympathize with him Sheoraj Singh extracted from him in the course of conversation an admission that he had taken part in the crime and also the names of a number of his accomplice.

    The Kanungo reported what he had learnt on the 17th of May, and on the 7th of June, Jamna Das was arrested. Three days later Abdul Wahab and the appellants who had been named by Jamna Das were arrested. Meanwhile Sadua? had been talking about the dacoity in a way which showed that he had personal knowledge of it. Apparently he, too, had a grievance over the division of the spoils. He spoke to Harnam Singh, who is the samdhi of Ram Sarup, and in this way the information came to the ears of a constable named Lal Singh and on the 16th of July Sadua was arrested. On the 2nd of October he made a confession, which was recorded by a Magistrate under section 164 of the Code of Criminal Procedure. It is argued that the value of this confession must be discounted owing to the time which elapsed before it was made, but we find that no questions on this point were put to Sadua in cross-examination or to the police, and there does not appear to be any reason to suppose that the confession was inspired by the police or its materials supplied by them to Sadua. He has adhered to his confession throughout and has been made an approver. Cross-examination has failed to betray him into any contradictions or inconsistencies. His statement has been abundantly corroborated by the testimony of other witnesses. In addition to this the approver took a Magistrate over the scene of the dacoity and the route taken by the dacoits and produced a kathla which he said he had received as part of his share of the plunder. This kathla has been satisfactorily identified, and the Magistrate's evidence proves that Sadua was able to point out accurately where the various occurrences of the dacoity had taken place and in a manner that tallied exactly both with his own statement and with the evidence of the eye-witnesses. We agree with the learned Judge that the approver's statement may be relied on and is a valuable piece of evidence.

    The accused were paraded for identification in the Haldwani jail. Owing to the scarcity of other under trial prisoners in that jail, outsiders were brought in and placed in the line with them. This procedure has been criticized, and it was no doubt unusual, but in the peculiar circumstances of the case no other course could have been adopted and the evidence of the Magistrate who conducted the parade shows that every possible precaution was taken to prevent unfairness. The witnesses were strangers to Haldwani and while outsiders were being collected and taken into the jail they were all kept under the Magistrate's eye near the police station. They thus had no opportunity of seeing them before the parade.

    The evidence against the accused consists in the main of the identifications made at the jail by the eye-witnesses, of the statement of the approver and of the confession of Jamna Das. As is always the case, the most important evidence is that of the identifications. The learned Sessions Judge has considered this evidence carefully and where in his opinion it was insufficient he has given the accused the benefit of the doubt and acquitted them. In no instance has he accepted less than two identifications in the jail as adequate corroboration of the approver's evidence. There is, however, one error in his proceedings which might have seriously affected the legality of several of the convictions, though, as it happens, there is in this case sufficient evidence against all the accused who are affected by it. Certain witnesses were unable to identify in the Sessions court, one or more accused whom they had identified at the jail. This is not unnatural, as an interval of eight months elapsed between the identification and the trial, and the appearance of several of the accused had considerably altered in the meantime. In these cases the learned Judge has treated the jail identification as direct evidence against the accused, without anything to link it up with the evidence given in court. As was pointed out in Nagma v. Emperor , for a Magistrate or other officer to come into court and depose that a particular witness in his presence identified one of the accused as having taken part in the dacoity is nothing more than hearsay evidence. The Magistrate's evidence a mounts in substance to this: “The witness said in my presence that a particular accused whom he pointed out took part in the dacoity.” The statement of the witness is not made on oath, and it is not made in court. The statement can only he proved either to corroborate the evidence which the witness after words wives in court, in accordance with section 157 of the Evidence Act, or under some other provision of the Evidence Act. If the witness at the trial is no longer able to recognize the accused, there are two ways in which his previous statement can be rendered admissible. The statement made by the witness before the committing Magistrate may be brought on the record under section 288 of the Code of Criminal Procedure. This was the course adopted in Nagina v. Emperor . It is only available where the witness was able to pick out the accused before the committing Magistrate though he could not do so before the Judge. The other method is to elicit from the witness at the trial a statement that he identified certain persons at the jail and that the persons whom he there identified were persons whom he had seen taking part in the dacoity. If the witness is prepared to swear this, then it is open to the court under section 9 of the Evidence Act to establish by other evidence the identity of the accused whom the witness identified at the jail. For this purpose the best evidence will be that of the Magistrate who conducted the identification, and his evidence will be strictly relevant under the provisions of the Evidence Act. Of the witnesses who failed to pick out in the Sessions Court persons whom they had previously identified, the only one who fulfils these conditions is Tulshi Gir, who deposes that he saw some of the dacoits and that he recognized those same persons again at the identification before the tahsildar at the Haldwani jail. If the case of any of the accused had depended entirely on the evidence of witnesses who were unable to pick him out at the Sessions, it would have been necessary to send back the case to supply the omission in the learned Judge's record. As it happens, however, there is no accused against whom there if not at least one reliable identification in addition in the evidence of the approver.

    We note here that the learned Judge says towards the close of his judgment that “the rulings are unanimous that a man cannot be legally convicted on the uncorroborated testimony of an accomplice.” If this be correct, all we can say is that the rulings in question have repeated section 133 of the Evidence Act, which no court is competent to do. The learned Judge will find the law correctly laid down in Mahant Narain Das v. The Crown (2), and various other rulings which have hitherto escaped his notice.

    [The rest of the judgment was occupied with discussion of the evidence against each of the accused. The final order of the Court was as follows:—]

    We dismiss the appeals of Abdul Wahab, alias Habbu Khan. Muhammad Saved Khan and Jamna Pas confirm the sentences of death passed upon them and direct that these be carried out according to law.

    We dismiss the appeals of Ghuima Khan, Shabrati, Abdul Rahim Khan, alias Abdul, Prem, Sahib Singh, Ganga Ram, Alijan, son of Chheda Khan, Alijan, son of Ahmad Bakhsh, Jairaj, Lala, alias Tjalla, Jhabba, Behari, Nur Bakhsh, alias Nuri, Umrao and Baljit, and confirm the sentences of transportation for life passed upon them.

    The further sentence of forfeiture passed under section 92 of the Indian Penal Code must be set aside as that section has been repealed by Act No. XVI of 1921.

    Appeals dismissed and convictions upheld.

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    Comments

    Emperor v. Abdul Wahab And Others
    (Jul 21, 1924)