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RAM NARAIN V. STATE OF UTTAR PRADESH

Ram Narain v. State of Uttar Pradesh (1973) 2 SCC 86

ISSUE:

  • Whether the legality and propriety of the Appellant’s conviction on the uncorroborated testimony of the hand-writing expert valid?

RULE:

  • The opinion of a handwriting expert is not conclusive evidence; however, it may be deemed acceptable if supported by internal or external evidence related to the document in question that corroborates the expert’s conclusions.
  • The court may also conduct its own comparison of handwriting to verify the expert’s findings, provided the presiding officer is familiar with the language and writing style involved.

FACTS:

  • On August 15, 1964, a five-year-old boy named Mannu went missing from the home of his relative, Gajendra Natth, in Kanpur, Uttar Pradesh.
  • A report was filed at the Sisamau police station, and a reward of Rs. 501 was announced for information leading to the child’s recovery.
  • Two anonymous letters were received by Gajendra Natth; the first demanded a ransom of Rs. 1,000, and the second demanded Rs. 5,000 for the return of Mannu.
  • In December 1964, Yashpal Singh, a trainee from a local ITI, provided information leading to Mannu’s recovery on January 11, 1965.
  • The investigation implicated Ram Narain as responsible for the kidnapping and sending the ransom letters.
  • Ram Narain was charged under Sections 363 (kidnapping), 468 (forgery), and 384/511 (attempt to commit robbery) of the Indian Penal Code.
  • The trial court convicted Ram Narain under Section 384/511 IPC based solely on handwriting analysis that linked him to the ransom letters.
  • The conviction was upheld by the Temporary Sessions Judge of Kanpur on appeal.
  • Ram Narain’s revision petition was dismissed by the Allahabad High Court on October 6, 1969.
  • The case reached the Supreme Court of India via a special leave petition.

HELD:

  • The Supreme Court examined whether Ram Narain’s conviction based solely on handwriting expert testimony was legally sound.
  • It acknowledged that while handwriting expert opinions are fallible and should be treated with caution, they can be accepted if corroborated by other evidence or if the court itself verifies similarities through comparison.
  • The court found that all three lower courts had compared the disputed writings with known samples and concluded they matched Ram Narain’s handwriting.
  • The Supreme Court upheld the conviction due to sufficient corroboration from both expert testimony and judicial comparison.
  • The sentence of rigorous imprisonment for one year was deemed appropriate but was reduced to the time already served due to significant delays in proceedings since the crime occurred.