Showing posts with label res gestate. Show all posts
Showing posts with label res gestate. Show all posts

Thursday, 4 February 2016

When evidence of bystander is admissible?

Sec.6 of the Evidence Act is an exception to the general

rule whereunder the hearsay evidence becomes admissible. But for

bringing such hearsay evidence within the provisions of S.6, what is

required   to  be    established   is  that  it  must    be   almost

contemporaneous with the acts and there should not be an interval

which would allow fabrication. The statements sought to be

admitted, therefore, as forming part of res gestate, must have been

made contemporaneously with the acts or immediately thereafter

[(see Sukhar v. State of U.P. (1999 (9) SCC 507)].




       Where the transaction consists of different acts, in

order that the chain of such acts may constitute the same

transaction, they must be connected together by proximity of time,

proximity or unity of place, continuity of action and community of

purpose or design.      The spontaneity of the statement is the

guarantee of the truth.    The reasons for its admissibility under

Section 6 of the Evidence Act is that it is a part of the transaction

and not merely because it is spontaneous.         The statement is

relevant only if it is that of a person, who had seen the actual

occurrence and who uttered it simultaneously with the incident or

soon thereafter as to make it reasonably certain that the speaker is



still under the stress of the excitement caused by his having seen

the incident.   In order to make the statement of a bystander

admissible, it must have been made, at the time of transaction or

shortly before or after it. The statement uttered or the act done must

be a spontaneous reaction of the person witnessing the crime and

forming part of the transaction. The bystanders' declaration must

relate only to that which came under their observation.[See

Bhaskaran v. State of Kerala (1985 KLT 122)]. In the present

case, the declaration was made by the victim himself, immediately

after the incident     of sustaining     injury by him. In the said

circumstances, the      evidence of PW5 and PW6 about what the

victim/deceased said immediately after the incident, is admissible

under Section 6 of the Evidence Act. The above discussion would

make it clear that apart from Sec.32 (1) of the Evidence Act, the

aforesaid statement of the deceased can be admitted under Sec.6

of the Evidence Act on account of its proximity of time to the act of

murder. In either case, whether it is admissible under S.32 (1) or

under S.6 of the Evidence Act, it is substantive evidence, which can

be acted upon with or without corroboration in finding guilt of the

accused [(see Rattan Singh's case (supra)].


IN THE HIGH COURT OF KERALAAT ERNAKULAM

                              PRESENT:

            THE HONOURABLE MR.JUSTICE K.T.SANKARAN
                                  &
        THE HONOURABLE MR. JUSTICE B.SUDHEENDRA KUMAR

        FRIDAY, THE 5TH DAY OF JUNE 2015

                    CRL.A.No. 1157 of 2010 (G)



       AHRAF, S/O.MOIDU,
           THARAYIL VEEDU, VELLARKAD,
           ERUMAPETTY, PUNNAYOOR,
           THRISSUR DISTRICT.

   Vs

           THE STATEOF KERALA,
           

Citation: 2015(3)KLJ201
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