Motive is immaterial where credible direct ocular evidence independently proves the accused’s guilt.

The appellant was convicted by the Sessions Judge, Jorhat, in Sessions Case No. 169(J-J)/2014 for murdering his brother, Samra Sawtal, by striking him with a naga dao while the deceased was sleeping at home.

The incident occurred on 21 September 2014, and the appellant’s daughter, PW-1, lodged the FIR, leading to registration of Borholla P.S. Case No. 82/2014 under Section 302 of the Indian Penal Code (IPC).

The Trial Court examined seven prosecution witnesses, convicted the appellant, and sentenced him to life imprisonment with a fine of ₹10,000, with a further six months’ rigorous imprisonment in default of payment.

In appeal, the appellant challenged the conviction and sentence.

PW-1, the appellant’s daughter, and PW-2, his son, claimed to have witnessed the appellant attack the deceased with a dao.

Other witnesses corroborated the immediate disclosure of the incident and observed the deceased’s injuries.

The post-mortem revealed two chop wounds, including a deep injury to the back of the head, which was sufficient to cause death in the ordinary course of nature and was homicidal in character.

The Investigating Officer seized the naga dao allegedly used in the offence.

The appellant denied the allegations in his examination under Section 313 of the Code of Criminal Procedure, 1973 (CrPC), but offered no specific explanation.

1. Whether the prosecution proved beyond reasonable doubt that the appellant intentionally caused the death of his brother, thereby committing murder punishable under Section 302 IPC?

2. Whether the absence of an established motive, and the possibility that the appellant was intoxicated, created reasonable doubt warranting interference with the conviction?

3. Whether the conviction and sentence imposed by the Trial Court required appellate interference?

The Court applied Section 302 IPC, which prescribes punishment for murder, read with the offence of murder under Section 300 IPC.

It applied Section 374 CrPC concerning an appeal against conviction.

The Court relied on the principle that credible and consistent direct ocular testimony can establish guilt even in the absence of proof of motive, and that motive assumes greater significance primarily in cases based on circumstantial evidence.

The Court also referred to Section 86 IPC, observing that voluntary intoxication does not ordinarily exempt an accused from criminal liability where the requisite knowledge may be attributed to him.

Medical evidence corroborating the eyewitness account was treated as material evidence supporting the prosecution case.

The Court found PW-1 and PW-2 to be eyewitnesses whose testimony remained consistent in material particulars and was not discredited in cross-examination.

Their evidence was corroborated by PW-3, PW-4, and PW-6, who received immediate disclosures regarding the assault and observed the deceased’s bleeding injuries.

The post-mortem evidence established that the deceased had sustained deep chop wounds caused by a heavy sharp-edged weapon and that the head injury was sufficient to cause death in the ordinary course of nature.

The seizure of the naga dao further supported the prosecution case.

Although no motive was proved, the Court held that motive was not decisive in view of the direct ocular evidence.

The suggestion that the appellant’s habitual drunkenness explained the offence did not assist him, particularly because intoxication did not negate liability under Section 86 IPC.

The appellant’s bare denial under Section 313 CrPC did not create reasonable doubt.

The absence of a proved motive and the alleged intoxication did not undermine the reliable eyewitness and medical evidence.

The Court found no ground to interfere with the conviction under Section 302 IPC or the sentence of life imprisonment and fine imposed by the Trial Court, and accordingly dismissed the appeal.

The Trial Court Record was directed to be returned, and the Legal Aid Counsel’s fees were ordered to be paid according to the applicable norms.