Recently, the Supreme Court examined a criminal case involving allegations of murder, caste-based abuse, and a village dispute arising out of an alleged elopement. The matter raised serious questions over the reliability of eyewitness testimony, hostile witnesses, inconsistencies in medical evidence, and the prosecution’s failure to examine independent witnesses despite the incident allegedly occurring on a busy public road.
Brief Facts :
The case arose from an alleged assault where the accused was stated to have attacked the deceased with a stone following a dispute connected to the deceased’s earlier elopement with the accused’s sister. The prosecution claimed that the deceased later succumbed to the injuries and that the deceased’s mother was also abused with caste-related remarks during the incident. Consequently, offences under Sections 302 and 323 of the Indian Penal Code, 1860 and Sections 3(1)(x) and 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 were invoked. The Trial Court convicted the accused and the High Court affirmed the conviction, leading to the appeal before the Supreme Court
Contentions of Appellant :
The counsel for the Appellant argued that the prosecution case suffered from major contradictions as the alleged eyewitness turned hostile and denied material parts of the prosecution story. It was further contended that no independent witness was examined despite the incident allegedly occurring on a busy public road. The appellant also challenged the credibility of the medical evidence by pointing out discrepancies in the postmortem report and sought acquittal from offences under Sections 302 and 323 IPC and Sections 3(1)(x) and 3(2)(v) of the SC/ST Act.
Contentions of State :
The State contended that the testimony of the deceased’s mother, the recovery of the blood-stained stone, and the forensic evidence sufficiently proved the prosecution case. It was argued that the testimony of a hostile witness is not completely effaced from the record and can still be relied upon to the extent it supports the prosecution case.
Observation of the Court :
The Court observed that the prosecution evidence suffered from serious contradictions and inconsistencies which weakened the entire case. The Court found it significant that the alleged eyewitness turned hostile and contradicted the prosecution narrative, while no independent witness was examined despite the incident allegedly taking place on a busy public road. The Court also doubted the reliability of the medical evidence because of discrepancies in the postmortem report and inconsistencies regarding the timing of the autopsy.
“the evidence of a prosecution witness cannot be rejected in toto merely because the prosecution chose to treat him as hostile and cross-examined him.”
The Court further clarified the evidentiary value of hostile witnesses and observed, “The aforesaid legal position leaves no manner of doubt that the evidence of a hostile witness remains admissible evidence, and it is open to the court to rely upon the dependable part of that evidence which is found to be acceptable and duly corroborated by some other reliable evidence available on record…”
While assessing the prosecution case, the Court held that “the occurrence of incident itself could not be said to have been proved by the prosecution.” The Court further remarked that “the prosecution miserably struggled to be finally unable to prove its case” and ultimately concluded that “the conviction recorded by the Trial Court and confirmed by the High Court is not sustainable.”
Decision of the Court :
The Supreme Court allowed the appeal and set aside the judgments of the Trial Court and the High Court. The Court held that the prosecution failed to prove offences under Sections 302 and 323 IPC and Sections 3(1)(x) and 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 beyond reasonable doubt. Accordingly, the appellant was acquitted and directed to be released forthwith unless required in any other case
Case Title: Talari Naresh v. The State of Telangana
Case No.: SLP (Crl.) No. 13614 of 2025
Coram: Hon’ble Mr. Justice Prashant Kumar Mishra and Hon’ble Mr. Justice N.V. Anjaria
Advocate for the Appellant: Mr. D. Ramakrishna Reddy, Mrs. D. Bharathi Reddy, Advocate-on-Record, and others
Advocate for the Respondent: Mr. Kumar Vaibhaw, Mr. Devina Sehgal, Advocate-on-Record, and others
Read Judgment @Latestlaws.com
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