Court’s Decision:
The Supreme Court set aside the conviction of 13 accused persons in a double murder case after holding that the testimony of the alleged eyewitness was unreliable and uncorroborated. The Court held that “a serious dent is created in the prosecution story and it becomes difficult to accept the presence of the so-called eyewitness at the place of occurrence.” It further observed that “[t]he testimonies of the witnesses do not inspire confidence, and there are glaring contradictions and inconsistencies.” The appeal was allowed and all the accused were acquitted of charges under Sections 147, 148, 302 read with 149 of the Indian Penal Code.
Facts:
The case arose out of a violent incident in which two individuals were murdered following a land-related dispute. The prosecution alleged that 13 accused persons, all armed, had attacked the deceased with deadly weapons including pistols and sticks. The FIR was lodged the same day by an alleged eyewitness who claimed to have witnessed the entire attack. The trial court convicted all accused under various provisions including murder, and the High Court upheld the convictions.
The key witness was a relative of the deceased, and the entire prosecution case was based on his testimony. However, no bloodstains were found at the alleged crime scene, and the medical and forensic evidence did not conclusively support the prosecution’s version. This led to the Supreme Court re-evaluating the credibility of the eyewitness testimony.
Issues:
- Whether the sole eyewitness account was credible enough to sustain the conviction of all accused?
- Whether the inconsistencies in the testimonies and lack of corroborative evidence rendered the prosecution case unreliable?
- Whether the High Court erred in affirming the trial court’s decision without due scrutiny of material inconsistencies?
Petitioner’s Arguments:
The petitioners argued that the eyewitness was not present at the scene of the crime and that his testimony was fabricated. They contended that there were numerous contradictions between his account and the medical and forensic evidence. They also pointed out that there was no recovery of weapons, no bloodstains, and no forensic confirmation tying the accused to the crime scene. The delay in examining witnesses and the improbability of the incident unfolding in broad daylight in a crowded area were also highlighted to question the veracity of the prosecution’s story.
Respondent’s Arguments:
The State contended that the conviction was based on an eyewitness who had no reason to falsely implicate the accused. The State emphasized that minor discrepancies in witness testimonies were to be expected and should not dilute the core of the prosecution’s case. It was further submitted that the medical evidence supported the claim of a violent assault, and the consistency in the sequence of events narrated by the eyewitness lent credibility to his deposition.
Analysis of the Law:
The Court reiterated the principle that while a conviction can rest on the testimony of a sole eyewitness, such testimony must be of sterling quality and free from any material contradictions or improvements. The Court cited earlier judgments holding that the reliability of such testimony must be evaluated with circumspection, especially when the witness is related to the deceased.
It was noted that improvements and omissions in statements under Section 161 and 164 of the Criminal Procedure Code, and contradictions with medical evidence, can seriously undermine the prosecution’s case.
Precedent Analysis:
The Court referred to the following landmark decisions:
- State of Rajasthan v. Smt. Kalki (1981) – Held that minor discrepancies do not demolish the entire prosecution case.
- Vijay Kumar Arora v. State (2022) – Reiterated that improvements in the prosecution story are fatal when they touch upon material aspects.
- Ganpat Singh v. State of M.P. (2017) – Emphasized the need for corroboration when the sole eyewitness is an interested witness.
- Lallu Manjhi v. State of Jharkhand (2003) – Held that corroboration is essential in case of related witnesses.
- Beni Ahmad v. State of U.P. (1976) – Highlighted that inconsistencies can shake the foundation of the prosecution’s case.
These decisions were relied upon to emphasize that the courts must carefully scrutinize evidence when the prosecution case hinges on a single interested witness.
Court’s Reasoning:
The Court carefully analyzed the inconsistencies in the eyewitness’s version and observed that his story had improved over time and contradicted medical records. The non-recovery of weapons, absence of blood at the scene, and delay in the investigation weakened the prosecution case further. The Court remarked that “there is a clear attempt to falsely implicate the accused by planting an unreliable version of the incident.”
The Court was particularly critical of the High Court’s failure to re-evaluate evidence while affirming the conviction and held that it had mechanically upheld the trial court’s order without considering the weaknesses in the prosecution’s case.
Conclusion:
The Supreme Court concluded that the entire conviction rested on a solitary witness whose testimony was inconsistent, uncorroborated, and unreliable. In view of the contradictions and absence of supporting evidence, the Court acquitted all 13 accused. The appeal was allowed and the judgments of both the trial court and the High Court were set aside.
Implications:
This judgment reinforces the principle that when the prosecution relies solely on an interested witness, their testimony must be scrutinized with utmost care. The ruling also emphasizes the importance of corroborative evidence, forensic support, and a fair investigation. The decision will serve as a precedent in cases involving mass conviction based on singular accounts and will guide future courts on the evidentiary thresholds required for such convictions.
Referred Cases and Their Relevance:
- State of Rajasthan v. Smt. Kalki (1981) – Discussed the role of minor contradictions; found not applicable due to material contradictions in the present case.
- Vijay Kumar Arora v. State (2022) – Cited to underscore the fatal effect of improvements in statements.
- Ganpat Singh v. State of M.P. (2017) – Relied upon to question the reliability of a sole interested witness.
- Lallu Manjhi v. State of Jharkhand (2003) – Applied to stress that corroboration is essential for related witnesses.
- Beni Ahmad v. State of U.P. (1976) – Used to show that inconsistencies undermine the prosecution’s credibility.
FAQs:
Q1: Can a conviction be based solely on a single eyewitness?
Yes, but the testimony must be wholly reliable, consistent, and credible. If the eyewitness is interested or related to the deceased, corroboration becomes essential.
Q2: What weakens an eyewitness account in a criminal trial?
Contradictions with medical evidence, lack of forensic support, improvements or omissions in statements, and the absence of recovery or bloodstains can render the testimony unreliable.
Q3: What role does the High Court play in upholding trial court convictions?
The High Court must independently scrutinize the evidence and cannot affirm convictions mechanically. It is expected to re-appreciate material on record.
