Court’s Decision
The Allahabad High Court set aside the conviction of the appellant under Section 302 of the Indian Penal Code, holding that the prosecution failed to prove the charge of murder beyond reasonable doubt. The Court emphasized that the prosecution’s case was built primarily on a single eyewitness whose testimony suffered from material contradictions and improbabilities. It observed that “when the evidence of the star witness collapses, the foundation of the prosecution case also crumbles,” and consequently extended the benefit of doubt to the accused.
Facts
The prosecution alleged that the accused had murdered the deceased with a firearm following a dispute. An FIR was promptly registered naming the accused. Investigation led to the recovery of weapons and other incriminating material, and the charge sheet was filed.
At trial, the prosecution relied heavily on the testimony of a single eyewitness, who claimed to have seen the accused committing the act. The trial court found this evidence sufficient and convicted the accused under Section 302 IPC, sentencing him to life imprisonment.
On appeal, the accused challenged the veracity of the eyewitness testimony, pointed to inconsistencies in the prosecution story, and contended that the medical and forensic evidence did not support the prosecution’s case.
Issues
- Whether the conviction could be sustained on the sole testimony of the eyewitness despite material inconsistencies.
- Whether the medical and ballistic evidence corroborated the prosecution version.
- Whether the prosecution proved guilt beyond reasonable doubt as required under criminal law.
Petitioner’s Arguments
The appellant argued that the trial court erred in convicting him on the basis of unreliable testimony. The eyewitness’s account was riddled with contradictions, such as the sequence of events, distance of observation, and conduct after the incident. It was contended that the witness was a chance witness with personal animosity, making his testimony suspect.
The appellant further submitted that the medical evidence did not align with the eyewitness’s account of the assault, and that no independent witnesses were examined despite the alleged presence of several people. The ballistic evidence was also inconclusive, and recovery of the weapon was doubtful. Relying on principles of criminal jurisprudence, the appellant urged that benefit of doubt must be given where the prosecution’s case is not free from reasonable doubt.
Respondent’s Arguments
The prosecution defended the conviction, asserting that the testimony of a solitary eyewitness, if credible, is sufficient to base a conviction. It argued that the witness was natural and consistent on material particulars, identifying the accused and narrating the incident. The prosecution further submitted that minor contradictions do not demolish the prosecution case, and medical evidence broadly supported the version.
It also contended that the motive was clearly established through previous enmity, and the trial court rightly placed reliance on the testimony. The State urged the High Court not to interfere with the concurrent findings of guilt recorded at trial.
Analysis of the Law
The Court revisited settled legal principles that conviction can rest on the sole testimony of an eyewitness provided it is cogent, credible, and trustworthy. However, if the testimony suffers from infirmities, contradictions, or is inconsistent with medical or circumstantial evidence, the Court must be cautious. The burden is always on the prosecution to prove guilt beyond reasonable doubt, and failure to remove such doubt entitles the accused to acquittal.
Precedent Analysis
The Court relied on several Supreme Court rulings:
- Vadivelu Thevar v. State of Madras – held that conviction can be sustained on testimony of a single witness if wholly reliable.
- State of Rajasthan v. Teja Ram – emphasized that medical and ocular evidence must be reconciled, and when contradictions arise, ocular evidence must be of sterling quality.
- Kali Ram v. State of Himachal Pradesh – reiterated that if two views are possible, the one favoring the accused must be adopted.
These precedents guided the Court in evaluating the present case and reinforced that the benefit of doubt cannot be denied where the prosecution evidence is shaky.
Court’s Reasoning
The Court found that the eyewitness’s presence at the scene was doubtful and that his testimony was inconsistent with the medical findings. The conduct of the witness after the incident was unnatural, and the FIR appeared to have been lodged with embellishments. Further, the ballistic evidence did not conclusively establish that the firearm allegedly recovered was the weapon of offence.
Given these infirmities, the Court held that the trial court erred in convicting the accused without corroborative evidence. The contradictions went to the root of the prosecution case, and reliance on such evidence would amount to miscarriage of justice.
Conclusion
The High Court allowed the appeal, set aside the conviction, and acquitted the accused of all charges under Section 302 IPC. The Court held that the prosecution failed to prove the case beyond reasonable doubt and reiterated that in criminal law, suspicion, however strong, cannot take the place of proof.
Implications
This judgment underscores the principle that conviction cannot rest on shaky or doubtful evidence, even when there is a named eyewitness. It strengthens the jurisprudence on benefit of doubt and the necessity of corroboration when the sole eyewitness account is unreliable. The ruling reinforces the importance of balancing ocular testimony with medical and forensic evidence, ensuring that wrongful convictions are avoided.
FAQs
Q1: Can a person be convicted solely on the testimony of one eyewitness?
Yes, but only if the testimony is wholly reliable and consistent. If it suffers from contradictions or improbabilities, conviction cannot be sustained.
Q2: What happens if medical evidence contradicts eyewitness testimony?
Courts generally give primacy to ocular evidence, but if contradictions are irreconcilable, medical evidence prevails, and benefit of doubt goes to the accused.
Q3: What is the principle of benefit of doubt in criminal cases?
If the prosecution’s case leaves reasonable doubt about guilt, the accused must be acquitted. Suspicion cannot substitute legal proof.