TEAM CODE: TZ-05

MANIPAL 1 ST NATIONAL TRIAL ADVOCACY COMPEITITON 2021

IN THE COURT OF THE HON’BLE SESSIONS JUDGE

AT PRAYAG SHEHAR

STATE OF

(PROSECUTION)

V.

RAMESH, SURESH, MUKESH AND ORS.

(DEFENSE)

FOR OFFENCES CHARGED UNDER:

OFFENCES PUNISHABLE UNDER SECTION 302, 323, 324, 147, 14, 149, 336 AND
427 OF IPC AND OF THE INDIAN PENAL CODE, 1860 UNDER SECTION 4/25 OF
ARMS ACT.

UPON SUBMISSION TO THE HONOURABLE SESSIONS JUDGE

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TABLE OF CONTENTS

1. INDEX OF AUTHORITIES
2. STATEMENT OF JURISDICTION
3. STATEMENT OF FACTS
4. STATEMENT OF ISSUES
5. SUMMARY OF ARGUMENTS
6. ARGUMENTS ADVANCED
7. PRAYER
8. LIST OF WITNESS

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INDEX OF AUTHORITIES

TABLE OF CASES
1. Awdhesh and Ors v. State of MP, AIR 1988 SC 1158
2. State of Punjab v. Rakesh Kumar (1998) Cr LJ 3604 (SC)

3. Dr S.L. Goswami v. State of Madhya, AIR 1972 SC 716.

4. Jaswinder Singh v. State of Punjab, CRA-S-2794-SB-2016
5. state of Rajasthan v. Raja Ram, (2003) 8 SCC 180.
6. Upendra Pradhan v. State of Orissa, (2015) 5 SCC 634
7. Sujit Biswas v. State of Assam, (2013) 12 SCC 406.
8. Akhilesh Kumar v. State of U.P, (2016) 95 ACC 170.

BOOKS

1. Sarkar, Law of Evidence, (13th Ed,1990)

2. Saxena & Gaur, Arms and Explosives, (10th Ed. 2012)
3. Sharma, B.R., Forensic Science in Criminal Investigation & Trials, (4th Ed. 2003)
4. Tyagi, Surendra Prakash, Criminal Trial (2nd ed. 1996)
5. Varshi, H.P. Criminal Trial and Judgment, (3rd ed. 1981)
6. Ratanlal and Dhirajlal, The Indian Penal Code, 33rd Ed. (2011)

WEBSITES
1. http://www.manupatra.co.in/AdvancedLegalSearch.aspx
2. http://www.scconline.com

STATUTES
1. The Code of Criminal Procedure, 1973 (Act 2 of 1973)
2. The Indian Evidence Act, 1872 (Act 18 of 1872)
3. The Indian Penal Code, 1860 (Act 45 of 1860)

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STATEMENT OF JURISDICTION

This Hon’ble Court has jurisdiction to try the instant matter under Section 177 read
with Section 209 and Section 184(b) read with Section 223 and Section 219 of the
Code of Criminal Procedure, 1973.

Section 177:
‘177. Ordinary place of inquiry and trial-
Every offence shall ordinarily be inquired into and tried by a Court within whose
local jurisdiction it was committed.’

Read with Section 209:

‘209. Commitment of case to Court of Session when offence is triable exclusively
by it-
When in a case instituted on a police report or otherwise, the accused appears or
is brought before the Magistrate and it appears to the Magistrate that the offence
is triable exclusively by the Court of Session, he shall-
(a) commit the case to the Court of Session;
(b) subject to the provisions of this Code relating to bail, remand the accused to
custody during, and until the conclusion of, the trial;
(c) send to that Court the record of the case and the documents and articles, if
any, which are to be produced in evidence;
(d) notify the Public Prosecutor of the commitment of the case to the Court of
Session.’

Section 184(b):
‘184. (b) -
the offence or offences committed by several persons are such that they may be
charged with, and tried together by virtue of the provisions of section 223,
the offences may be inquired into or tried by any Court competent to inquire into
or try any of the offences.’

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Section 223:
‘223. –
The following persons may be charged and tried together, namely;
a) persons accused of the same offence committed in the course of the same
transaction;
b) accused of more than one offence of the same kind, within the
meaning of section 219 committed by them jointly within the period of twelve
months;
c) persons accused of different offences committed in the course of the same
transaction;

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STATEMENT OF FACTS
1. Alam is a 19 y/o resident of Prayag Shehar. Four days prior to present day (i.e.,
21/02/21), there was a fight between a group of unknown people and Salman, Adnan,
Dinesh (and several others) and a couple of others near Babu’s shop. Alam decided to
intervene with this commotion.
2. The brother of Alam, the deceased filed an FIR on 21.02.2021 at Laxminagar, Prayag
Shehar, and the contents of it is as follows:-
i. On 21/02/21, at 7:30 PM, Alam, Raja and Avinash were standing with their friends at
the street of Metranjan shop. Ramesh, Suresh, Mukesh, Adnan and Salman along with
15 other people arrived at the said place and started beating up Alam, Raja and
Avinash.
ii. The Complainant (Alam’s brother) immediately ran to the scene to find Ramesh,
Suresh, Mukesh, Adnan and Salman assaulting Alam. Tarnum (Tannu) also arrived
the crime scene.
iii. As the complainant reached the crime spot he witnessed that Suresh, Mukesh, and
Adnan assaulting his brother, Alam. Raj and Avinash were also injured during the
accident. After hurting the three victims (Alam, Raja and Avinash) the accused fled
the place of incident in a motorcycle.
iv. Alam was taken to LML hospital by his brother (the complainant) and Alam was
declared dead on arrival by the doctors.
v. The post mortem report suggested the following:
 The cause of death was shock brought about as a result of antemortem
 The death was a result of injury no.8, associated with injury no.9.
 Injury 8 & 9 were individually and cumulatively responsible for the death of the
victim.
 All the injuries were antemortem in nature and were caused in the last 24 hours.
 Injury no. 1,2,3,4,5,6 and 7 were caused due to a blunt weapon.
 Injury no. 7 & 8 were caused by a sharp, double edged weapon.
vi. Various articles such as a sharp edged knife, motorcycle and blood stained clothes
recovered from the accused
vii. An FIR was recorded against Ramesh, Suresh, Mukesh, Adnan, Salman and 15 other
people for committing offences under Sections 302, 323, 324, 147, 14, 149, 336 and
427 of the IPC and under section 4/25 of Arms act.
3. This matter is listed hearing.

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STATEMENT OF ISSUES

ISSUE- 1
WHETHER THE ACCUSED PERSONS (SURESH AND ORS) ARE GULITY
OF MURDER?

ISSUE- 2
WHETHER THE ACCUSED PERSONS ARE GUILTY OF UNLAWFUL ASSEMBLY
AND RIOTING?

ISSUE- 3
WHTEHER THE ACCUSED PERSONS IS GUILTY OF THE OFFENCE OF
GREVIOUS HURT & ENDANGERING HUMAN LIFE?

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SUMMARY OF ARGUMENTS

ISSUE- 1
WHETHER THE ACCUSED PERSONS (SURESH AND ORS) ARE GULITY
OF MURDER?

It is submitted that the accused parties are not to be guilty of murder since there is neither
proof for mens rea nor for the actus reas. The accused parties do not have any pre-meditated
motive or intention to cause any sort of harm to the deceased. Further, it is submitted that the
witness statements are ambiguous, inconsistent and unreliable and cannot and should not be
held against the accused, creating a genuine case of reasonable doubt and gives them a
benefit of doubt.

ISSUE- 2
WHETHER THE ACCUSED PERSONS ARE GUILTY OF UNLAWFUL ASSEMBLY
AND RIOTING?

It is humbly submitted before this honorable court by the prosecution that Ramesh, Suresh,
Mukesh, Adnan, Salman and 15 other people (hereafter referred to as ‘Accused’) is not guilty
of charges under section 147,148 & 149 of the Indian penal Code, 1860 because the accused
did not form an unlawful assembly of more than 5 people with a common object to hurt the
victim and there was no force or violence used by this unlawful assembly.

ISSUE- 3
WHTEHER THE ACCUSED PERSONS IS GUILTY OF THE OFFENCE OF
GREVIOUS HURT & ENDANGERING HUMAN LIFE?

It is submitted that the accused are not guilty as it cannot be proved beyond reasonable doubt
that there was an intention to cause hurt and endanger life and to prove that the act was
committed because the evidences and the witnesses presented are not reliable, and are
contradictory in nature.

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ARGUMENTS ADVANCED

ISSUE-1
WHETHER THE ACCUSED PERSONS (SURESH AND ORS) ARE GULITY
OF MURDER?

It is humbly contented that the accused persons are not guilty for offence of murder under §
300 1 of the Indian Penal Code, and hence the charge against the accused under S. 302 does
not stand.

A culpable homicide is essentially a murder if there is an intention to cause death, and it an

act was done with the knowledge and intention of causing an injury so dangerous that it is
likely to cause death. 2

It is humbly submitted that accused parties are not guilty of murder, since (1) they do not
have any reason or intention to have hurt or murdered the deceased person, Alam, (2) the
prosecution has relied on inconsistent evidences, and are there discrepancies in the oral
testimonies of the witnesses.

1.1. THERE WAS NO INTENTION

It is submitted that it is essentially upon the prosecution to prove the intention of the accused
parties to murder Alam. Nevertheless it is contended that the accused parties do not have any
pre-meditated motive or intention to in any way cause harm to the deceased. It is pointed out
that there is nothing that shows why the accused parties would want to murder the deceased.

It has not been established by any of the statements from the witness as to the intention of the
accused to hurt the Alam, Raja Khan and Avinash.

It is the mental element of the accused alone, which is material to decide whether a particular
act is culpable homic ide amounting to murder, or culpable homicide not amounting to

1Section 300- Murder- Except in the cases hereinafter excepted, culpable homicide is murder —
1.If the act by which the death is caused is done with the intention of causing death, or
2.If it is done with the intention of causing such bodily injury as the offender knows to be likely to cause the
death of the person to whom the harm is caused. or
3.If it is done with the intention of causing bodily injury to any person and the bodily inju ry intended to be
inflicted is sufficient in the ordinary course of nature to cause death, or
4.If the person committing the act knows that it is so imminently dangerous that it must, in all probability,
cause death, or such bodily injury as is likely to cause death, and commits such act without any excuse for
incurring the risk of causing death or such injury as aforesaid.
2 PSA Pillai, Criminal Law 12th Edition.

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murder.3 It can hence be seen this instant case, that since there is no evidence to show the
intention of the accused, it is submitted that the accused persons has no mens rea or intention.

1.2. UNRELIABLE EVIDENCES AND BENEFIT OF DOUBT

It is to submitted that witnesses being unreliable, inconsistent and inaccurate, there is a

reasonable doubt that the accused persons have in this instant case. A reasonable doubt must
not be imaginary, trivial or merely possible doubt; but a fair doubt based upon reason and
common sense arising out of the evidence of the case. 4

As per the statements of PW1, it is to be noted that Shri Moeen Ali arrived at the place of the
said crime after hearing the loud noises and he stated that he saw the accused persons
assaulting Alam, and that all three of them (Alam, Raja Khan and Avinash) were stabbed and
wounded.

This shows that the PW1 is not a witness for the said offence of murder, and hence it is
submitted that his statements and testimonies cannot and should not be taken into account as
a proof for murder by the accused parties.

Further PW2 stated that he saw three people near Alam and being stabbed, it is to be noted
that Alam had ran towards Hatwada road and Raja Khan states that he was hit on his face and
was bleeding, and in this state, it is highly impossible for him to have identified who stabbed
Alam, and the same is in his statement, where he has not stated who stabbed Alam.

This is hence, submitted is not conclusive proof for the murder of Alam.

It is to be noted that as per the written statements given by PW3, Avinash, he tried to escape
from the scene and came back only after Alam was stabbed and on the ground, and hence his
testimony as to if the accused persons are guilty of murdering Alam cannot be taken into
consideration and is to be held an improper witness for this purpose, as his evidence is
completely and in its entirety unreliable.

It is submitted that PW2 stated that the incident happened on 20.09.2020 near Chacha
Chawla Shop, whereas the FIR and every other testimony shows that the event took place on
21.09.2020. Furthermore it is to be noted that PW3 said that the even took place in Uncle
Chai Wale, which shows an inconsistency in the place of event as stated by both PW 2 and 3.

4 Awdhesh and Ors v. State of MP, AIR 1988 SC 1158.

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Furthermore, it is humbly submitted that it seems very unlikely that the incident that
happened in the middle of the street in front of the tea shop has only has as witnesses the
brother of the deceased and his two friends who were said to be there, and not even the
people who run the shop.

The Apex Court has held that in cases where there are a number of infirmaries in the
evidence of the eyewitnesses the benefit of the doubt is given to the accused 5, bearing in
mind that PW 1, 2, 3 had not seen the accused commit the actus reus, and it has already been
submitted that there is no mens rea. It would be thus be highly unsafe to convict the accused
for the crime.

ISSUE-2

WHETHER THE ACCUSED PERSONS ARE GUILTY OF UNLAWFUL ASSEMBLY

AND RIOTING?
It is humbly submitted before this honorable court by the defense counsel for Ramesh,
Suresh, Mukesh, Adnan, Salman and 15 other people (hereafter referred to as ‘Accused’) is
not guilty of charges under section 147, 148 & 149 of the Indian Penal Code, 1860 6 (hereafter
referred as ‘IPC’). It is to be noted that in order for the accused to be culpable under these
section, they have to fulfil all the essential elements of the offence of rioting which is
enshrined in section 146 IPC are as follows:

1. The accused persons must be 5 or more in number and form an unlawful assembly;
2. The accused must be animated by a common object; and
3. The force or violence must be used by the unlawful assembly or any member thereof
in the prosecution of the common object.

It is humbly contended that the accused did not commit the offence rioting or any form of
unlawful assembly[2.1], that there was no common object between the accused and that there
are major discrepancies in the written statement[2.2], coupled with heavy reliance by the
Prosecution on unreliable circumstantial evidence [2.3]

2.1 THE ACCUSED DID NOT COMMIT THE OFFENCE OF RIOTING

5State of Punjab v. Rakesh Kumar (1998) Cr LJ 3604 (SC)

6
Indian Penal Code, 1860 (Act 45 of 1860)
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The defence counsel hereby submits before this honourable court that the accused persons of
this person did not commit the offence of rioting. In order to establish that the accused are
guilty of rioting, the prosecution should establish that they fulfil all the criteria for rioting
which they have clearly failed to do. Prior to doing the same, the Prosecution ought to prove
that the accused were bound by common object towards the alleged rioting which lead to the
death of the victim, Alam.

It is essential for the court to note that nothing can be concluded which hasn’t been proven
beyond reasonable doubt. The counsel for the Defense, wishes to invoke at this juncture, the
case of Dr S.L. Goswami v. State of Madhya where the Supreme Court of India held that, “It
is well settled that the burden on the accused is not as onerous as that which lies on the
prosecution. While, the prosecution is required to prove its case beyond reasonable doubt,
the accused can discharge his onus by establishing a mere preponderance of probability.” 7

In another case that the counsel for defense deems fit to mention is the case of Jaswinder
Singh v. State of Punjab where the Hon’ble High Court held that, “It is settled law that the
prosecution is to prove its case beyond reasonable doubt. But in the present case as the link
in evidence is missing therefore it cannot be held that prosecution has proved its case
regarding link evidence.”8
However, in the present case the link in evidence has been loosely tied by the Prosecution in
an attempt to form a chain of events. Having failed to prove such beyond the reasonable
doubt, the onus of burden of proof continues to be on the prosecution.

2.2 THERE ARE MAJOR DISPARANCIES IN THE WRITTEN STATEMENT

The Defense Counsel humbly submits before this Hon’ble Court that the case of the
Prosecution is unreliable owing to the factual discrepancies in the written statements of the
witnesses which give the defense a wide berth to question the facts of the case as well as
provides the benefit of doubt to the Accused.

Alluding to the said written statements of the witness, the Defense first takes into account the
statement put forth by Shri Moen Ali, brother of the deceased and eye witness of the incident.
In his testimony, the number of members of the assembly of the Accused is stated as:-
“Ramesh, Suresh, Mukesh, Adnan and Salman along with 15 other people”, which accounts

7
Dr S.L. Goswami v. State of Madhya, AIR 1972 SC 716.
8
Jaswinder Singh v. State of Punjab, CRA-S-2794-SB-2016.
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for the total number of Accused to be 19 people. On the contrary, referring to the statements
of Mr. Raja Khan and Shri Avinash, the Accused were 8-10 in number, which accounts for a
deficit of 9-11 people when read with Shri Moen Ali’s statement. There seems no plausible
reason for such incorrect facts as stated.

It is also submitted that the testimonies are contradictory in nature owing to the fact that Shri
Moen Ali states, and emphasis must be laid on the same, that in an attempt to rescue the
deceased from the alleged assault, Mr. Raja Khan and Shri Avinash, were “stabbed and
wounded” in the process and also that Shri Moen Ali was the one to take the deceased to
LML Hospital with the aid of the motorbike of one named Shabbir. This seems highly
unreliable when read along with the testimony of Shri Avinash whose statement neither
provides any hint to any attempt on part of Mr. Raja Khan and Shri Avinash to rescue Alam
from the alleged assault, whatsoever, nor does it state that either of them were stabbed.
Reference must also be made to the statements of Mr. Raja Khan wherein he state s that he
had assisted Shri Moen Ali in carrying the deceased to the Hospital and it cannot be helped
but question must be raised as to whether a person who has been “stabbed and wounded” is
capable of assisting someone else to be carried to the hospital. To a prudent person, answer to
the same would be in the negative. It must also be mentioned that the date of the incident
altogether is stated as 20.09.2020 whereas the other two witnesses have stated the same to be
21.02.2021. Such discrepancies lead to question the credibility of the witnesses.

As stated earlier, these discrepancies in the written statements raise questions as to the chain
of events and also provide a window to bestow the Accused with benefit of the doubt. The
Counsel for the Defence alludes to the following case laws to substantiate its stance-

The Hon’ble Supreme Court’s judgement pronounced in the case of State of Rajasthan v.
Raja Ram 9, recently reiterated in Upendra Pradhan v. State of Orissa 10-

“The golden thread which runs through the web of administration of justice in criminal cases
is that if two views are possible on the evidence adduced in the case, one pointing to the guilt
of the accused and the other to his innocence, the view which is favourable to the accused
should be adopted. The paramount consideration of the Court is to ensure that miscarriage of
justice is prevented. A miscarriage of justice which may arise from acquittal of the guilty is
no less than from the conviction of an innocent.”

9 State of Rajasthan v. Raja Ram, (2003) 8 SCC 180.

10 Upendra Pradhan v. State of Orissa, (2015) 5 SCC 634.
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The judgement of the Hon’ble Apex Court, in the matter of Sujit Biswas v. State of Assam11
also alludes to the benefit of doubt that must be given to the Accused owing to loopholes and
discrepancies of the Prosecution and credibility of the witness-

“This is for the reason that the mental distance between ‘may be’ and ‘must be’ is quite
large, and divides vague conjectures from sure conclusions. In a criminal case, the court has
a duty to ensure that mere conjectures or suspicion do not take the place of legal proof. The
large distance between ‘may be’ true and ‘must be’ true, must be covered by way of clear,
cogent and unimpeachable evidence produced by the prosecution, before an accused is
condemned as a convict, and the basic and golden rule must be applied. In such cases, while
keeping in mind the distance between ‘may be’ true and ‘must be’ true, the court must
maintain the vital distance between mere conjectures and sure conclusions to be arrived at,
on the touchstone of dispassionate judicial scrutiny, based upon a complete and
comprehensive appreciation of all features of the case, as well as the quality and credibility
of the evidence brought on record. The court must ensure, that miscarriage of justice is
avoided, and if the facts and circumstances of a case so demand, then the benefit of doubt
must be given to the accused...”

The division bench of Hon’ble High Court of Allahabad in Akhilesh Kumar v. State of UP12
held that that factual chain of circumstances is broken and the version of the prosecution has
not been established as was required of it. In the absence of complete chain, the guilt of the
accused cannot be inferred.

The Counsel for the Defense further puts forth that the incident described by the witnesses
does not provide the whole story and background which must have lead to the impugned
incident which can be partly inferred from Shri Moen Ali’s statement. Therefore, owing to
faulty chain of events as presented by the Prosecution, want of more judicial scrutiny and
reasonable benefit of doubt and the golden rule in crimina l trials as stated in the
aforementioned case laws, the Defense Counsel humbly submits that the Accused ought not
be convicted of the charges so levied against them.

2.3 CIRCUMSTANTIAL EVIDENCE IS UNRELIABLE

It is a well settled principle that where the case is mainly based on circumstantial evidence,
the court must satisfy itself that various circumstanced in the chain of evidence should be

11 Sujit Biswas v. State of Assam, (2013) 12 SCC 406.

12 Akhilesh Kumar v. State of U.P, (2016) 95 ACC 170.
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established clearly and that the completed chain must be such as to r ule out a reasonable
likelihood of the innocence of the accused13 .

When even a link breaks away, the chain of circumstances gets snapped and other
circumstances cannot in any manner establish the guilt of the accused beyond all reasonable
doubts. 14 When attempting to convict on circumstantial evidence alone the Court must be
firmly satisfied of the following three things:15

i. The circumstances from which the inference of guilt is to be drawn, must have fully
been established by unimpeachable evidence beyond a shadow of doubt
ii. The circumstances are of determinative tendency, unerringly pointing towards the
guilt of the accused
iii. The circumstances taken collectively, are incapable of explanation on any reasonable
hypothesis except that of the guilt sought to be proved against him

ISSUE 3
WHTEHER THE ACCUSED PERSONS IS GUILTY OF THE OFFENCE OF
GREVIOUS HURT & ENDANGERING HUMAN LIFE?
It is humbly submitted that the accused are not guilty of causing grievous hurt or endangering
human life. Firstly, there is no mens rea to do any such act and secondly, there is no proof
beyond reasonable doubt that such as actus reus is present. The prosecution has to prove the
guilt of the accused beyond reasonable doubt. 16

The primary element of any crime is mens rea. It is submitted that there is no reason for the
accused to have an intention or motive to cause hurt to Alam and friends, and this intention
has not been shown by any of the witnesses in their statements. Hence it is submitted that
since there is no mens rea, the accused cannot be held guilty.

Secondly, it is to be noted that there are discrepancies between different statements made in
the Medical Report17.

13
Mohan Lal v. State of Uttar Pradesh AIR 1974 SC 1144.
14
Janar Lal Das v. State of Orissa, (1991) 3 SCC 27; A. Jayaram and An r. v. State of AP, AIR 1995 SC 2128.
15
Mahmood v. State of UP, AIR 1976 SC 69.
16 State of Gujarat v Bai Fatima AIR 1975 SC 1478
17 Annexure 2, Medical Report.

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In the heading of “ii. Injuries on body”, all injuries and bleedings have been filled out as
“N/A” or not applicable which essentially shows that there has not been an injury or
bleeding. While they have also submitted some wounds later on in the report.

It is humbly submitted this is a clear case of ambiguous and unreliable piece of evidence and
hence cannot be taken into account fully.

Further in the Autopsy Report 18, it is to be noted that injuries 1-7 have been caused by blunt
weapon and injuries 7 and 8 by sharp weapon. It is contented that is a serious discrepancy
and this holds the whole of the autopsy report unreliable.

It is to be noted that as per the written statements given by PW3, Avinash, he tried to escape
from the and hence his testimony as to if the accused persons are guilty of grievous hurt and
endangering life cannot be taken into consideration and is to be held an improper witness for
this purpose, as his evidence is completely and in its entirety unreliable.

It is submitted that PW2 stated that the incident happened on 20.09.2020 near Chacha
Chawla Shop, which is the incorrect date, as the event took place on 21.09.2020. Furthermore
it is to be noted that PW3 said that the even took place in Uncle Chai Wale, which shows an
inconsistency in the place of event as stated by both PW 2 and 3.

Furthermore, it is humbly submitted that is extremely unlikely that the incident that happened
in the middle of the street in front of the tea shop has only has as witnesses the brother of the
deceased and his two friends, and Tarnum, whose statements have not been recorded
whatsoever, and not even the people who run the shop are included as witnesses of this case.

It is hence humbly submitted that there is a reasonable doubt as to the commission of the
offence, and there is no conclusive proof incriminating the accused, which means that they
are to be acquitted of these charges.

18 Annexure 3, Autopsy Report.

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PRAYER

Wherefore, in light of the issues raised, arguments advanced and authorities cited, may
this Hon’ble Court be pleased to adjudge and declare that:

1. The accused is not guilty of Murder

2. The accused is not guilty of unlawful assembly and rioting
3. The accused is not guilty of the offence of grievous hurt and endangering human life

AND/OR

Pass any other order it may deem fit, in the interest of Justice, Equity and Good
Conscience.
All of which is most humbly and respectfully submitted

FOR THIS ACT OF KINDNESS, THE DEFENCE SHALL FOREVER BE DUTY BOUND.

Place: Prayag Shehar S/d_____________

Date: COUNSEL FOR THE DEFENSE

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