Supreme Court Refuses to Restore Murder Conviction; Upholds Acquittal Holding Stereotyped Eyewitness Testimony and Medical Contradictions Failed to Prove Guilt Beyond Reasonable Doubt
Supreme Court Upholds Acquittal; Rules Medical Evidence Contradicted Prosecution’s Version of Fatal Assault
Facts
The appeals were filed by the informant (mother of the deceased) and the State of Maharashtra challenging the Bombay High Court’s judgment acquitting twenty accused who had earlier been convicted by the Trial Court for offences under Sections 302, 307, 147, 148 and 149 IPC.
According to the prosecution, on 18 March 2014 (Holi festival), a quarrel arose when the deceased Avinash requested that a DJ be stopped near his grandmother’s house. Later that afternoon, when Avinash, his father, brother and cousin returned home, they were allegedly dragged by a group of accused persons and assaulted with iron pipes, iron bars and wooden planks. Avinash died due to head injuries while the other three sustained injuries.
The Trial Court convicted twenty accused and sentenced them to life imprisonment. However, the Bombay High Court reappreciated the evidence and acquitted all the accused by granting them the benefit of doubt, leading to the present appeals before the Supreme Court.
Issues
- Whether the High Court was justified in reversing the Trial Court’s conviction and acquitting the accused.
- Whether the ocular evidence of the injured and eyewitnesses was reliable despite alleged identical narration of events.
- Whether the contradictions between the ocular and medical evidence created reasonable doubt.
- Whether the Supreme Court should interfere with the High Court’s order of acquittal under Article 136 of the Constitution.
Petitioner’s Arguments
The informant and the State contended that:
- The Trial Court had correctly appreciated the evidence and convicted the accused.
- The testimony of injured witnesses carries greater evidentiary value and could not be discarded merely because several witnesses narrated similar facts.
- The eyewitness accounts stood corroborated by the medical evidence proving homicidal death and injuries caused by hard and blunt objects.
- Minor investigative lapses, including defects in sealing case property and delay in recording statements, could not outweigh otherwise reliable ocular evidence.
- The High Court ignored settled principles governing appreciation of injured witnesses and wrongly granted benefit of doubt.
Respondent’s Arguments
The accused contended that:
- Six prosecution witnesses narrated virtually identical details regarding the role of each of the twenty-three accused, indicating tutoring rather than independent recollection.
- The medical evidence fundamentally contradicted the prosecution version, particularly the allegation that four accused continuously assaulted the deceased’s head with iron pipes.
- Independent witnesses were not examined despite the incident occurring in a residential locality.
- Statements of key witnesses were recorded belatedly without satisfactory explanation.
- Serious defects in investigation, including discrepancies in the FIR, improper handling of seized articles and unexplained injuries sustained by the accused, created substantial doubt regarding the prosecution case.
- The High Court had adopted a reasonable view and its acquittal should not be disturbed under Article 136.
Analysis of the Law
The Supreme Court reiterated that:
- While exercising jurisdiction under Article 136, it ordinarily does not interfere with an acquittal unless the findings are perverse, manifestly illegal or grossly unjust.
- The evidence of an injured witness ordinarily deserves greater weight, but such testimony must still withstand judicial scrutiny.
- Criminal courts must assess the prosecution evidence as a whole, particularly where there are material inconsistencies between ocular and medical evidence.
- Defective investigation alone does not justify acquittal, but where substantive evidence itself is doubtful, investigative lapses assume significance and reinforce the benefit of doubt.
Precedent Analysis
The Court relied upon, inter alia:
- Lakshmi Singh v. State of Bihar — identical and stereotyped eyewitness versions may indicate tutoring and unexplained injuries on the accused may cast doubt on the prosecution case.
- State (Delhi Administration) v. Laxman Kumar and Himmat Sukhadeo Wahurwagh v. State of Maharashtra — cautioning against accepting parrot-like and stereotyped eyewitness testimony.
- Sanjay Kumar v. State of Bihar (2026 INSC 735) — holding that material inconsistency between ocular and medical evidence may justify sustaining an acquittal.
- Parshuram v. State of Madhya Pradesh — reiterating that failure to explain injuries sustained by the accused may indicate suppression of the true genesis of the occurrence.
- Babu Sahebagouda Rudragoudar v. State of Karnataka — reiterating the limited scope for interference with an acquittal.
The Court distinguished the authorities cited by the appellants regarding the weight to be attached to injured witnesses, observing that while their presence at the scene was unquestionable, that alone did not validate a detailed, identical attribution of roles to twenty-three accused.
Court’s Reasoning
The Supreme Court found that all six prosecution witnesses gave virtually identical accounts assigning specific roles, weapons and acts to each of the twenty-three accused. Such complete uniformity was considered unnatural and suggestive of tutoring rather than independent recollection.
The Court further noted a significant conflict between the ocular and medical evidence. While the prosecution alleged that four accused repeatedly struck the deceased’s head with iron pipes for several minutes, the post-mortem revealed only one lacerated injury on the scalp with an underlying fracture. The prosecution’s own medical expert admitted that such a version would ordinarily have resulted in multiple injuries or even a crushed skull.
The Court also attached significance to:
- unexplained delay in recording statements of eyewitnesses;
- failure to examine independent witnesses despite the occurrence taking place in a populated locality;
- discrepancies in the FIR;
- defective handling of seized material;
- unexplained injuries sustained by several accused.
Considering these circumstances cumulatively, the Court held that the High Court had taken a reasonable and possible view in granting the accused the benefit of doubt. Since the acquittal was neither perverse nor manifestly illegal, the Supreme Court declined to interfere under Article 136 of the Constitution.
Conclusion
The Supreme Court held that the High Court’s acquittal was based on a reasonable appreciation of the evidence and did not suffer from perversity or manifest illegality warranting interference under Article 136.
Accordingly, the Court dismissed both the appeals filed by the informant and the State of Maharashtra and affirmed the acquittal of all the accused.
Case Details
Case: Nirmala Bai Devidas Chavhan v. State of Maharashtra & Others (with connected appeals)
Court: Supreme Court of India
Case Number: Criminal Appeal Nos. 502–507 of 2023 and Criminal Appeal Nos. 508–513 of 2023
Judges: Hon’ble Justice Sanjay Karol and Hon’ble Justice Augustine George Masih
Date: 03 August 2026
Result: Appeals dismissed. The Supreme Court upheld the Bombay High Court’s acquittal of all the accused and declined to restore the Trial Court’s conviction.
