Supreme Court of India on Acquittal in Murder Case due to Contradictory Witness Evidence

Headnote:

The Supreme Court of India allowed the appeal filed by Kannaiya and his co-accused, Govardhan, Raja Ram, and Bhima, and acquitted them of charges under Section 302 IPC. The Court found material contradictions and improbabilities in the prosecution evidence, including inconsistent accounts of the incident’s genesis and place, omission of key witnesses in the FIR, and conflicting testimonies from eyewitnesses Madho Singh (PW-5) and Puniya (PW-12). Observing that such contradictions rendered the prosecution case unsafe, the Court held that conviction could not be sustained. The appeal was allowed, and the accused were acquitted.

Background:

• The deceased, Ramesh, was allegedly assaulted by the appellants during a political rivalry.

• FIR alleged the incident began with demolition of a hut by the accused.

• Key eyewitnesses, Madho Singh (PW-5) and Puniya (PW-12), claimed to have witnessed the assault.

• The appellants challenged the conviction, highlighting contradictions in witness statements and omission of critical facts from the FIR.

Court’s Observations:

• Genesis and circumstances of the incident were inconsistently described.

• Omission of Puniya’s presence from the FIR raised doubts about the prosecution’s narrative.

• Madho Singh’s testimony conflicted with site inspection findings.

• Absence of corroborative evidence and inherent improbabilities made the prosecution case unsafe.

• Following precedents such as Vadivelu Thevar v. State of Madras, Pankaj v. State of Rajasthan, and Bhagwan Sahai v. State of Rajasthan, the Court held that conviction cannot be sustained when facts are doubtful.

Legal Provisions Discussed:

• Section 302, Indian Penal Code – Punishment for murder.

• Principles of criminal jurisprudence regarding evaluation of witness evidence, contradictions, and safe conviction.

Citation: 2025:SC:CR:2339

Case: Kannaiya & Ors. v. State of Maharashtra

Court: Supreme Court of India

Criminal Appeal No.: [CRIMINAL APPEAL No./SLP(CRIMINAL) 2339/2025]