Recently, the Supreme Court revisited the evidentiary standards required to sustain a conviction for murder, particularly where the prosecution case rests largely on the testimony of a related witness. The appeals arose from a judgment of the Chhattisgarh High Court affirming life sentences imposed on multiple accused, prompting the Supreme Court to examine whether the prosecution evidence met the threshold of proof beyond reasonable doubt.
Brief Facts:
The case arose from an incident in July 2010, when the deceased was allegedly assaulted near a village pond while bathing. An FIR was lodged by his mother, who claimed that she reached the spot after being informed by her granddaughter and witnessed the accused persons assaulting her son with sticks and stones. Following investigation, the accused were charged under Sections 302 read with 149 and 148 of the IPC. The Trial Court convicted them and sentenced them to life imprisonment, a decision later affirmed by the High Court, leading to the present appeals before the Supreme Court
Contentions of the Appellant:
The counsel for the Appellants contended that their conviction was unsustainable as it rested almost entirely on the testimony of the deceased’s mother, a closely related and interested witness whose evidence suffered from material contradictions. The counsel argued that her version regarding how she reached the place of occurrence and what she actually witnessed was inconsistent and unreliable. The Appellants further submitted that the prosecution failed to examine the granddaughter, who was allegedly the first informant and a crucial witness, thereby leaving a serious gap in the prosecution story. It was also pointed out that independent witnesses had turned hostile and did not support the alleged recoveries or the prosecution narrative, while the medical evidence did not clearly establish a nexus between the injuries and the weapons allegedly used. On these grounds, the appellants argued that the prosecution failed to prove guilt beyond reasonable doubt
Contentions of the State:
The State opposed the appeals, asserting that the testimony of a related witness cannot be discarded merely because of the relationship with the deceased. It was argued that the mother of the deceased was a natural witness whose presence at the spot was credible and whose testimony was consistent with the prosecution case in material particulars. The State further contended that the post-mortem evidence corroborated the occurrence of a violent assault and supported the prosecution version regarding the use of sticks and stones. It was submitted that minor contradictions and hostile independent witnesses could not dilute the overall strength of the prosecution case and that the Trial Court and High Court had rightly appreciated the evidence while recording the conviction.
Observation of the Court:
The Supreme Court reiterated the settled position of law that the testimony of a related or interested witness cannot be rejected solely on that ground, but must inspire confidence upon careful scrutiny. After examining the evidence of the deceased’s mother, the Bench observed that “there are material contradictions in her deposition regarding the manner in which the incident took place and with regard to which the information about the incident was given by her granddaughter.” The Court noted that while she claimed to have witnessed the assault, her testimony did not remain consistent on crucial aspects of the prosecution story.
The Court placed significant reliance on the admissions made by the eyewitness during cross-examination. It recorded that she had admitted that “when she reached at the place, the accused persons were standing there and Goreylal was injured,” and further that “she was not in a position to state as to which accused’s stick and which accused’s stone had hit the deceased.” In view of these admissions, the Bench categorically held that “simply relying upon the deposition given by PW-4, conviction cannot be recorded.”
The Bench further found fault with the prosecution for withholding a crucial witness. It noted that the granddaughter, who allegedly gave the first information and prompted the eyewitness to reach the spot, was not examined at all. The Court observed that this omission assumed greater significance when independent witnesses had failed to support the prosecution case. The judgment records that PW-2 and PW-3 “did not support the case of the prosecution,” and therefore “the recovery/production of the weapons from/by the accused persons through their memorandum of statement also cannot be believed.”
On the medical evidence, the Court expressed serious doubt about the prosecution narrative. While the post-mortem revealed multiple incised wounds, the Bench observed that only one stone was seized and shown to the doctor. The Court found it “difficult to believe that three incise wounds have been caused by one stone,” particularly when the doctor admitted that he had “the doctor, who had conducted the postmortem of the dead body of the deceased specifically stated that three incise wounds were found on the dead body of the deceased.” In light of these cumulative infirmities, the Court concluded that the prosecution had failed to establish the guilt of the accused beyond reasonable doubt
The decision of the Court:
The Supreme Court allowed the appeals and set aside the convictions and sentences upheld by the High Court. Holding that the prosecution failed to prove the case beyond reasonable doubt, the Court acquitted all the Appellants. Their bail bonds were accordingly discharged.
Case Title: Punimati & Anr. V. The State Of Chhattisgarh & Ors.
Case No.: Criminal Appeal No. 3647 of 2025
Coram: Hon’ble Mr Justice Prashant Kumar Mishra and Hon’ble Mr Justice Vipul M. Pancholi
Counsel for the Appellant: AOR Dushyant Parashar, Adv. Manu Parashar and Adv. Dinesh Pandey.
Counsel for the Respondent: Advocate General Avdhesh Kumar Singh, Adv. Prerna Dhall, Adv. Shivam Ganeshia, Adv. Ambuj Swaroop, Adv. Kapil Katare, Adv. Rajnandani Kumari, Adv. Dhananjay Kumar Singh and Adv. Prashant Singh, AOR.
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