Appeal against conviction in murder case. The case involved an assault resulting in death, with several family members as accused. Initially, a Trial Court acquitted all accused due to perceived inconsistencies in witness testimony and lack of corroboration from medical evidence, as well as an alleged lack of clear motive. However, the High Court reversed this decision for most accused, finding the Trial Court’s assessment flawed and placing undue emphasis on minor discrepancies while overlooking significant evidence including credible eyewitness accounts and corroborating medical findings. The Supreme Court upheld the High Court’s judgment, agreeing that minor inconsistencies do not invalidate eyewitness testimony and that the medical evidence, when viewed holistically, supported the prosecution’s case, finding the Trial Court’s initial acquittal to be perverse.
(A) Penal Code, 1860, Sections 302/ 34 – Murder – Perverse judgment – Judgment of acquittal by trial Court reversed by High Court – Held that a judgment is deemed perverse when it ignores material evidence, misinterprets facts, or arrives at conclusions that do not appear to be reasonable on the basis of the evidence presented – High Court identified several such errors in the Trial Court’s judgment, including disregarding credible eyewitness testimony without adequate justification; misinterpreting the medical evidence and using it to erroneously contradict eyewitness accounts; placing undue reliance on minor inconsistencies while ignoring the overwhelming evidence of guilt; failing to consider the sequence of events and the conduct of the accused in its entirety – High Court’s approach is consistent with established judicial precedents regarding the evaluation of evidence in criminal cases – This Court has repeatedly held that minor inconsistencies in witness testimony should not overshadow the truth of their statements – Similarly, it has been emphasized that medical evidence should be viewed as an aid to corroborate eyewitness accounts rather than as the sole determinant of facts – High Court adhered to these principles while assessing the evidence in this case, ensuring that its findings were grounded in sound legal reasoning – The brutal nature of the attack and the coordinated actions of the accused demonstrated clear intent to cause grievous harm, leading to the victim’s death – Trial Court’s acquittal of the accused not only undermined the credibility of the justice system but also sent a troubling message about the consequences of such heinous acts – . Therefore, the High Court’s judgment represents a well- reasoned and legally sound decision that rectifies the errors of the Trial Court and ensures that justice is served – The evidence on record, when assessed in its entirety, establishes the guilt of the accused beyond reasonable doubt – High Court’s observations regarding the reliability of the eyewitness testimony, the corroborative nature of the medical evidence, and the perverse findings of the Trial Court are compelling and do not warrant any interference.
(Para 43 to 36)
(B) Penal Code, 1860, Sections 302/34 – Murder – Testimony of related witnesses – Appreciation of evidence – Though the eyewitnesses who have been examined in the present case were closely related to the deceased, namely his wife, daughter and son, their testimonies are consistent with respect to the accused persons being the assailants who inflicted wounds on the deceased – As is revealed from the sequence of events that transpired, one of the family members was subjected to an assault – It was thus quite natural for the other family members to rush on the spot to intervene – The presence of the family members on the spot and thus being eyewitness has been well established – In such circumstances, merely because the eyewitnesses are family members, their testimonies cannot be discarded solely on that ground.
(Para 30)
(C) Penal Code, 1860, Sections 302/34 – Evidence – Inconsistence in oral and medical evidence – Trial Court based its findings on perceived inconsistencies between the testimony of the eyewitnesses and the medical evidence – Specifically, the Trial Court found fault with the eyewitness account of multiple stick blows to the victim’s head, contending that the post-mortem report did not show multiple head injuries – However, the High Court, after analysing the evidence holistically, pointed out that minor inconsistencies in eyewitness accounts do not render their testimony unreliable, especially when they pertain to incidents involving sudden and brutal violence – . It has been consistently laid down by this court that once there is a version of eyewitness and the same inspires confidence of the court it will be sufficient to prove the guilt of the accused – A conviction can be based upon the version put forth by the eyewitness and the medical evidence must be considered only for the purpose of corroboration of the ocular evidence.
(Para 31 to 33)
(D) The term ‘Interested witness’ – Related witness – Held that the term “interested” refers to witnesses who have a personal stake in the outcome, such as a desire for revenge or to falsely implicate the accused due to enmity or personal gain – A “related” witness, on the other hand, is someone who may be naturally present at the scene of the crime, and their testimony should not be dismissed simply because of their relationship to the victim – Courts must assess the reliability, consistency, and coherence of their statements rather than labelling them as untrustworthy – The distinction between “interested” and “related” witnesses is that a close relative is usually the last person to falsely implicate an innocent person – Therefore, in evaluating the evidence of a related witness, the court should focus on the consistency and credibility of their testimony – This approach ensures that the evidence is not discarded merely due to familial ties, but is instead assessed based on its inherent reliability and consistency with other evidence in the case.
(Para 28 and 29)
Baban Shankar Daphal V. State Of Maharashtra
Supreme Court: 2025 INSC 97: (DoJ 22-01-2025)
