The Supreme Court of India has affirmed the conviction and life sentence of individuals involved in a deadly conspiracy linked to liquor poisoning. In its ruling, the bench of Justices Sanjay Karol and Abhay S. Oka, referenced the influential case of State through Superintendent of Police v. Nalini, outlining the essential elements necessary to establish a criminal conspiracy. The Court reiterated the principle that all conspirators are accountable for individual offenses committed, emphasizing collective responsibility even for those who may not have actively participated in the commission of the offenses.
In 2003, an incident led to the deaths of seven people, the blindness of eleven individuals, and injuries to over 40 people due to alcohol poisoning. The conspiracy involved the unauthorized blending of methyl alcohol with spirit, orchestrated by individuals identified as A1 (referred to as 'Accused No. 1'), A3, A10, and A11. The goal was to illicitly gain profits through a business outlet operated by A1. The trial court convicted them in 2004, and this decision was upheld by the High Court. A1's Special Leave Petition (SLP) before the Supreme Court was dismissed in 2016, and subsequently, appeals were filed by A10 and A11.
Upon investigating the cause of death attributed to poisoning from methyl alcohol, the Supreme Court affirmed A1's involvement in the illegal liquor trade. Witness testimonies and evidence suggested that the appellants had connections with A1, methyl alcohol was stored at A1's residence, and A11, through RR Distributors, obtained Biosole containing 100% methyl alcohol, purportedly sold to multiple entities. Nevertheless, the accused buyers refuted any involvement in such transactions.
The Court, in referencing State v. Nalini, delineated the crucial elements of criminal conspiracy. Applying these principles, the Court determined that the prosecution had successfully demonstrated the criminal conspiracy involving A10 and A11 with A1.
This landmark case played a pivotal role in shaping the Supreme Court's comprehension of criminal conspiracy, establishing essential components for constituting such a conspiracy:
Agreement for Illegal Act or Legal Act by Illegal Means: Conspiracy entails an agreement between two or more individuals to either perform an illegal act or to achieve a legal act through illegal means.
Intent to Commit a Crime: The offense of criminal conspiracy necessitates not only the presence of intent but specifically an intention to commit a crime. This aligns with the shared intention among individuals involved.
Reliance on Inferred Circumstances and Conduct: Conspiracy is often established by examining inferred circumstances and the conduct of the accused. The Court relies on these factors to determine the existence of a conspiracy.
The Court in this case underscored a significant principle, affirming that all conspirators are liable for offenses committed individually in furtherance of the agreement. This liability extends to every member of the conspiracy, even if some did not actively participate in the actual commission of those offenses.
In the legal case of Yakub Abdul Razak Memon v. State of Maharashtra, the Supreme Court emphasized the significance of establishing an agreement between parties to prove a conspiracy. The Court ruled that criminal conspiracy is a collective responsibility, holding all conspirators accountable for the actions resulting from the conspiracy.
In dealing with the destruction of evidence by individual A11, the Supreme Court underscored its significance in bolstering the prosecution's account. Referencing the case of State of Haryana v. Krishan, the Court stressed the potential of evidence destruction in connecting accused individuals to broader conspiracies. The Court, taking note of the accused's inability to provide a valid explanation for incriminating circumstances, invoked the authority to draw unfavorable inferences.
Apart from the offences under the Indian Penal Code (IPC), the accused in question were found guilty under the provisions of the Abkari Act. Citing the precedent set in Chandran v. State of Kerala, the Court elucidated that Section 57(A)(1) of the Abkari Act applies to individuals mixing harmful substances with liquor, posing a potential threat to human life. The Court affirmed the constitutional validity of placing the burden of proof on the accused under this particular section.
In summary, the Court upheld the accused individuals' participation in the sale and adulteration of spirit with methyl alcohol as a component of the conspiracy, leading to fatalities and injuries. The convictions of A10 and A11 under Sections 302, 307, 326 of the Indian Penal Code (IPC), and 57(A)(1)(ii) of the Abkari Act were affirmed.
Case: Sajeev vs. State of Kerala,
Criminal Appeal No. 1134 of 2011.
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