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Supreme Court of India 2019-07-16 dismissed

MUNAWWAR vs THE STATE OF UTTAR PRADESH

Bench: 2 — Indira Banerjee, Sanjiv Khanna

In Brief

A seven-year-old boy was kidnapped on April 1, 1988, and subsequently found dead. The appellant was convicted along with co-accused for the murder and kidnapping under Sections 302, 365, and 201 IPC read with Section 34. On appeal, the appellant challenged the conviction citing the 'last seen' principle and FIR delay. The Supreme Court held that this was not a mere 'last seen' case: direct eyewitness evidence established the appellant took the boy into custody near a shop; the boy was familiar with the accused (his maternal uncles); and recovery of the body following a co-accused's disclosure statement further corroborated guilt. The reasonable FIR delay was excused due to ransom negotiations and fear for the victim's life. The Court affirmed the conviction with concurrent sentences of life imprisonment, seven years, and three years rigorous imprisonment.

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Criminal Law Murder Kidnapping Evidence - Eyewitness Circumstantial Evidence Burden of Proof Procedure - FIR Delay Child Victims

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