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Laxman Singh vs Poonam Singh & Ors on 10 September, 2003

In support of his submission, he has relied on a decision of the Supreme Court in Laxman Singh v. Poonam Singh (2003 Crl.L.J. 4478). That was a case where the accused had received injuries and so it was contended that they caused the murder of the victims mentioned in that case in exercise of their right of private defence. But it was held that the defence has to further establish that the injuries so caused on the accused probablises the version of the right of private defence. It was further held in that case that non-explanation of the injuries sustained by the accused at about the time of occurrence or in the course of altercation is a very important circumstance. But mere non-explanation of the injuries by the prosecution may not affect the prosecution case in all cases. These observations have been relied upon by the learned Public Prosecutor to canvass for the position that even in a case where the accused was proved to have sustained injuries, the preponderance of probabilities must be that the deceased was the aggressor and that the accused Crl.A.23/07 21 inflicted fatal injuries on the deceased when he had sustained injuries at the hands of the deceased and his men. But so far as this case is concerned, the deceased was unarmed and no injury whatsoever was caused or attempted to be caused to the accused and so the accused could not have a reasonable apprehension that death or grievous would be caused to him.
Supreme Court of India Cites 22 - Cited by 47 - A Pasayat - Full Document

Yogendra Morarji vs State Of Gujarat on 10 December, 1979

17. The learned counsel for the accused would submit that even though it would appear from the judgment, that before the court below no specific plea of right of private defence was putforward by the accused, the evidence and circumstances obtained in this case would probablise that the injuries must have Crl.A.23/07 15 been inflicted by the accused in exercise of his right of private defence. Learned counsel would further submit that if the court feels a genuine doubt that the true picture of the incident is not presented before it and when there is genuine doubt regarding the genesis of the incident, despite the fact that the plea of private defence was not specifically putforward by the accused and despite the fact that the accused could not prove or probablise the plea, still the prosecution cannot sustain its case unless the prosecution proved its case beyond reasonable doubt. Learned counsel further submits that it is only where the prosecution has proved its case with reasonable certainty that the court can raise the presumption regarding absence of circumstances bringing the case within any of the exceptions. It was held in Yogendra Morarji v. State of Gujarat [(1980) 2 S.C.C. 218]:
Supreme Court of India Cites 18 - Cited by 73 - R S Sarkaria - Full Document
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