Court’s decision
The Supreme Court upheld the conviction recorded by the trial court and affirmed by the appellate court, holding that minor contradictions in the prosecution evidence or non-recovery of every possible material object cannot nullify a conviction founded on clear, cogent and consistent testimony. The Court reiterated that the criminal justice system must not allow investigative lapses or omissions in procedural steps to overshadow reliable evidence of guilt. While emphasising the duty of the prosecution to conduct a fair, complete and professional investigation, the Court concluded that the omissions highlighted by the defence did not go to the root of the prosecution case and therefore did not warrant an acquittal.
Facts
The prosecutorial case rested upon the testimony of eyewitnesses who categorically stated that the accused inflicted fatal injuries on the victim during a sudden confrontation. The medical evidence corroborated the injuries described by the witnesses. The defence challenged the reliability of the prosecution by pointing out alleged inconsistencies regarding the weapon, the timing of medical examination, and the absence of certain recoveries. The trial court evaluated the oral and medical evidence and found the prosecution case fully established. The appellate court affirmed the conviction, observing that the essential ingredients of the charged offence stood proved beyond reasonable doubt. The matter then reached the Supreme Court.
Issues
- Whether discrepancies in the prosecution evidence relating to recovery, timing, or procedural steps undermine the foundational reliability of the case.
- Whether non-examination of certain witnesses or absence of certain documents constitutes a fatal flaw in a prosecution otherwise supported by direct evidence.
- Whether a criminal court can rely on eyewitness testimony despite the defence pointing out minor contradictions or improvements.
- Whether investigative lapses—such as non-seizure of all objects or incomplete documentation—can entitle an accused to acquittal despite clear substantive evidence of guilt.
Petitioner’s arguments
The petitioner argued that the prosecution case suffered from material contradictions, including the absence of recovery of the alleged weapon and inconsistencies in the narration of events. It was submitted that the prosecution failed to present the entire chain of circumstances and suppressed crucial facts, thereby violating the principles of fair investigation. The defence contended that non-recovery of the weapon raised reasonable doubt about the identity of the assailant, and the alleged discrepancies in medical timelines indicated fabrication. They emphasised the constitutional standard of proof beyond reasonable doubt and argued that in the presence of investigative lapses, the benefit of doubt must be extended to the accused.
Respondent’s arguments
The respondent State submitted that the conviction was based on reliable eyewitness testimony corroborated by medical evidence, and the alleged procedural irregularities were minor and immaterial. It was argued that conviction does not hinge on the perfection of investigation but on the reliability of substantive evidence. The State maintained that the omissions highlighted by the defence—such as non-recovery of all objects or alleged inconsistencies—were neither significant nor damaging to the core prosecution story. It further contended that the appellate court had independently evaluated the entire record and then sustained the conviction, leaving no basis for interference by the Supreme Court.
Analysis of the law
The Court analysed the jurisprudence on evidentiary contradictions and investigative lapses, reaffirming that criminal trials must focus on substantive truth rather than technicalities. It observed that eyewitness accounts, when consistent and corroborated by medical evidence, form a strong foundation for sustaining a conviction. The Court reiterated that discrepancies only become material when they strike at the root of the prosecution case. Procedural omissions—such as delayed recovery, incomplete documentation, or non-examination of some witnesses—cannot automatically result in acquittal unless prejudice is demonstrably caused. The Court emphasised that a perfect investigation is an ideal, but criminal justice cannot be allowed to collapse on account of imperfect investigations.
Precedent analysis
Although the judgment does not refer to multiple external authorities by name, it draws from well-settled principles consistently applied by the Supreme Court:
Doctrine of non-fatal contradictions
Courts have repeatedly held that minor contradictions or improvements do not corrode the prosecution case if core elements remain intact.
Principle that investigative lapses cannot benefit the guilty
In earlier decisions across several decades, the Supreme Court has clarified that the failure of police to conduct a perfect investigation cannot be exploited by an accused when eyewitness evidence is credible.
Rule of substantive corroboration
When medical findings support eyewitness testimony, the evidence gains greater probative value, outweighing technical gaps.
The present judgment follows these doctrinal lines, emphasising that courts must safeguard the truth-finding function rather than reward procedural shortcomings.
Court’s reasoning
The Court found that the eyewitness account was clear, consistent and natural, and there was no reason to doubt its credibility. The medical evidence aligned with the injuries described by the witnesses, thereby providing scientific corroboration. The Court noted that non-recovery of the weapon, alleged inconsistencies in timelines, or minor discrepancies in testimony did not strike at the heart of the prosecution case. It termed these “insignificant omissions” arising typically in human recollection and investigative limitations. The Court further held that fairness in investigation must be understood as an institutional duty, but imperfections cannot automatically erase the truth emerging from credible evidence. Therefore, the conviction warranted no interference.
Conclusion
The Supreme Court affirmed the conviction and rejected the petitioner’s attempt to characterise minor lapses as fatal defects. It held that the courts below had correctly appreciated the evidence, and that no perversity or miscarriage of justice was demonstrated. The judgment reinforces that the integrity of credible eyewitness and medical evidence outweighs procedural irregularities, and that the justice system must not allow technicalities to overshadow substantive truth.
Implications
This judgment strengthens the jurisprudence that investigative imperfections cannot become a tool for the guilty to escape conviction. It affirms the primacy of reliable substantive evidence in criminal adjudication. Trial courts and appellate courts are reminded that the pursuit of justice requires evaluating the entire evidence holistically rather than mechanically relying on technical lapses. For criminal practitioners, the decision underscores the importance of distinguishing genuinely material contradictions from trivial inconsistencies. For the justice system, it reaffirms that a fair trial is not synonymous with a perfect investigation, and that procedural shortcomings must not undermine credible and corroborated prosecution evidence.
