The Supreme Court has acquitted four individuals convicted of murder, citing unreliable witness testimonies and investigative delays that undermined the prosecution’s case.
New Delhi: The Supreme Court has acquitted four individuals previously convicted of murder, citing unreliable witness testimonies and delays in the investigation that cast serious doubt on the prosecution’s case.
The Court noted that
“the delay in recording the statements of key witnesses was “unfathomable” and raised concerns about the credibility of their testimonies”
The appeal was filed by four accused men challenging the Madhya Pradesh High Court’s decision, which had upheld their conviction and life imprisonment under Section 302 IPC read with Section 34 IPC for the murder of Mohan Singh.
A three-judge bench comprising Chief Justice Sanjiv Khanna, Justice Sanjay Kumar, and Justice K.V. Viswanathan ruled in favor of the appellants, emphasizing that the inconsistencies and contradictions in witness statements, coupled with unexplained investigative delays, rendered the evidence unreliable.
Case Background
The case revolved around the alleged murder of Mohan Singh, who was attacked after dropping off his friend, Vijay Dongre, at his village, Bhatkhadi. His father, Devisingh, lodged an FIR shortly after the incident, reporting that he had witnessed two individuals fleeing the crime scene—one of them identified as Ramlal, while the other was an unknown individual dressed in a suit and shoes.
The post-mortem report confirmed Mohan Singh’s homicidal death, citing multiple injuries, including head trauma and an abdominal gunshot wound.
During the trial, five men—Arun, Radheshyam, Narendra, Abhay Singh, and Ramlal—stood accused of the murder. The trial court sentenced them all to rigorous life imprisonment. However, the Madhya Pradesh High Court later acquitted Abhay Singh while upholding the conviction of the remaining four. Dissatisfied with this decision, the four convicts moved the Supreme Court.
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Supreme Court’s Observations and Ruling
The Supreme Court scrutinized the investigative lapses and inconsistencies in the prosecution’s case. The Bench particularly highlighted the delay in recording key witness statements:
- Abhay’s statement under Section 161 Cr.P.C. was recorded 17 days after the incident.
- Madhubala (PW-4) and Gopal (PW-8) also had their statements recorded 17 and 7 days later, respectively.
The Court found it puzzling that the Investigating Officer had taken such a long time to document these statements, despite the witnesses being readily available. This delay, the Bench noted, significantly compromised the reliability of their testimonies.
“This delay on the part of the Investigating Officer in recording the statements of these so-called crucial witnesses is unfathomable, given their availability and the versions given by them. It casts a cloud on the very veracity of their testimonies,”
the Bench remarked.
Furthermore, the Court pointed out contradictions between the FIR and the trial testimonies. Initially, Devisingh had only mentioned seeing Ramlal and an unidentified man at the crime scene. However, during the trial, he provided additional details and named other accused individuals, attributing specific roles to them. Such inconsistencies raised serious doubts about the prosecution’s narrative.
Enmity and the Principle of ‘Falsus in Uno, Falsus in Omnibus’
The Court also took into account the history of enmity between Mohan Singh’s family and some of the accused. While acknowledging that enmity can serve as both a motive for the crime and a basis for false implication, the Bench cautioned against convicting individuals based solely on questionable witness statements.
Addressing the legal principle of ‘Falsus in Uno, Falsus in Omnibus’ (false in one thing, false in everything), the Bench clarified that while Indian law does not require entire witness testimony to be discarded if certain parts are unreliable, courts must still exercise extreme caution before accepting such statements as evidence.
Doubtful Weapon Recovery and Medical Contradictions
Another key factor in the Court’s decision was the lack of solid forensic evidence. The prosecution heavily relied on the recovery of a 12-bore country-made pistol from Arun, one of the accused. However:
- No bullet was recovered from the victim’s body, even though he allegedly suffered a gunshot wound.
- The doctor who conducted the post-mortem later admitted that what was initially classified as a gunshot wound was actually caused by a stabbing weapon.
These contradictions further weakened the prosecution’s case, leading the Court to conclude that the evidence presented was insufficient to uphold the convictions.
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Verdict: Acquittal and Benefit of the Doubt
Considering the dubious oral testimonies, unexplained investigative delays, and contradictory medical and forensic evidence, the Supreme Court ruled that the prosecution failed to establish guilt beyond a reasonable doubt.
“As matters stand, the entire case of the prosecution hinges only upon the oral evidence of the family members of Mohan Singh, the deceased. However, as already noted hereinbefore, their evidence is found to be completely untrustworthy and specious. Conviction of the appellants cannot rest solely on such doubtful testimonies. The Trial Court and the High Court erred in the appreciation of this dubious oral evidence and in drawing the proper inferences therefrom,”
the Bench observed.
Accordingly, the Supreme Court allowed the appeal, set aside the conviction and sentence, and acquitted the four appellants.
This ruling reinforces the Supreme Court’s commitment to upholding the principles of fair trial and due process. By emphasizing the importance of timely investigations and scrutinizing witness credibility, the judgment serves as a precedent for ensuring that criminal convictions are based on credible and reliable evidence, rather than unsubstantiated allegations.
Case Details
Cause Title: Arun & Ors. v. State of Madhya Pradesh
Neutral Citation: 2025 INSC 406
Legal Representation
- Appellants: Senior Advocates Siddhartha Dave, Shikhil Suri, R.C. Mishra, AOR Pankaj Thaker, Advocates Nakul Chengappa, Shantanu Phanse, Prastut Mahesh Dalvi, Preet Phanse, Saurabh Jha, Vibhor Chaudhary, Ishita Ahuja, Madhu Suri, Jyoti Suri, AORs T.R.B. Sivakumar, Santosh Kumar Pandey, Advocates Ananya Mishra, Santosh Kumar Vishwakarma.
- Respondent: AOR Pashupathi Nath Razdan, Advocates Aditya Vaibhav Singh, Gautam Singh.
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