Court’s Decision:
The Karnataka High Court set aside the conviction and five-year sentence for attempted murder under Section 307 of the IPC, acquitting the appellant due to substantial inconsistencies in the victim’s sole testimony and lack of corroborative evidence. The Court found that the prosecution failed to prove the appellant’s guilt beyond a reasonable doubt.
Facts:
The case originated from an incident on April 25, 2009, in Vinayakanagara, Mysore, where the appellant allegedly kidnapped and injured the victim. The appellant reportedly dragged the victim into a car, took her to his home, and assaulted her with a knife, inflicting injuries to her abdomen. After escaping, the victim sought medical assistance and reported the incident, leading to charges under Sections 363 (kidnapping) and 307 (attempted murder) of the IPC.
Issues:
Whether the appellant was rightly convicted for attempted murder based on the victim’s sole testimony and circumstantial evidence.
Petitioner’s Arguments:
The defense argued that the injuries on the victim were self-inflicted and highlighted significant contradictions in her testimony. They questioned the nature of the injuries as they were not consistent with stab wounds. The defense argued that the lack of supporting evidence, especially from medical examinations and witnesses, weakened the prosecution’s case.
Respondent’s Arguments:
The prosecution contended that the victim’s testimony alone was sufficient for conviction, given her status as an injured witness. They argued that the trial court had rightly appreciated the evidence, and the conviction should be upheld based on her account.
Analysis of the Law:
Section 307 IPC mandates clear evidence to establish an intent to commit murder. In cases relying on sole witness testimony, courts generally require corroboration to validate the credibility of the witness, especially in the presence of contradictory statements or questionable evidence.
Precedent Analysis:
The defense cited multiple judgments (e.g., Khema v. State of U.P., Santosh Prasad v. State of Bihar) establishing that where witness credibility is in doubt, corroborative evidence becomes essential. The High Court emphasized these principles to argue that uncorroborated and inconsistent testimony could not substantiate a conviction.
Court’s Reasoning:
The Court scrutinized the victim’s statements and evidence inconsistencies, noting that her testimony was not “of sterling quality.” Contradictory details, such as the manner of injury and the lack of physical evidence matching her account, cast doubt on the authenticity of her statements. The Court also found it unlikely that the appellant could have inflicted such wounds given the lack of stab marks on the victim’s clothing.
Conclusion:
The Court concluded that the inconsistencies in the victim’s testimony and absence of corroborative evidence rendered the prosecution’s case unconvincing. The High Court extended the benefit of doubt to the appellant, acquitting him of the charges.
Implications:
This decision reinforces the principle that sole testimony, particularly with inconsistencies, must be approached cautiously. It underscores the importance of corroborative evidence in criminal cases, especially when the credibility of a key witness is in question.
