The Supreme Court clarified that a witness’s testimony cannot be rejected simply because they are related to the parties involved. Instead, such statements should be evaluated with greater care and scrutiny. The court emphasized that dismissing testimony based solely on familial ties could undermine the pursuit of justice. Each case demands an objective assessment of the credibility and relevance of the evidence presented.
New Delhi: The Supreme Court ruled that the mere fact that witnesses are relatives does not justify dismissing their testimony. Instead, their statements must be examined with heightened caution.
The Court highlighted that the incident arose from a sudden, heated altercation provoked by the deceased, and noted the absence of evidence indicating that the accused acted with cruelty.
The appeal contested the Patna High Court’s decision, which upheld the Additional Sessions Judge’s conviction of the appellant under Section 302 of the Indian Penal Code (IPC), resulting in a life sentence.
Justices B.R. Gavai and K.V. Viswanathan observed,
“A perusal of the evidence would therefore, reveal that there was no premeditation. The incident occurred on account of a quarrel that erupted between the deceased and the appellant on a trivial issue. The appellant appears to have lost his control and assaulted the deceased with the knife.”
In the case, PW-5 Ranglal Yadav, the deceased’s husband, alleged that on November 9, 2015, the appellant, annoyed by the removal of bricks from his door, began to verbally abuse the deceased. When she objected, he stabbed her in the chest, causing severe injuries, and fled the scene. The deceased later died in the hospital.
After the investigation, a charge sheet was filed, leading to the appellant’s life sentence. The High Court also dismissed his appeal. The appellant’s counsel argued that all witnesses were biased due to their relationship with the deceased and that there was insufficient evidence beyond their testimony. He contended that the case fell under Part I or II of Section 304 of the IPC, emphasizing the lack of premeditation and the spontaneous nature of the incident.
Conversely, the respondent’s counsel pointed out that five eyewitnesses consistently identified the appellant, highlighting the severity of the injury inflicted on a vital part of the body. The Bench concurred that the prosecution established the appellant’s responsibility for the death.
Addressing the issue of related witnesses, the Court stated,
“Merely because the witnesses are relatives cannot be a ground to discard the testimony of such witnesses. The only requirement is that the testimonies of such witnesses have to be scrutinized with greater caution and circumspection.”
The Bench concluded that the altercation was provoked by the deceased, with evidence indicating a single injury inflicted in a moment of anger. The Court determined that the appellant was entitled to the benefit of the exception under Section 300 of the IPC, reducing his conviction from Section 302 to Part I of Section 304.
Given that the appellant had already served nearly ten years in prison, the Court ordered his release, stating,
“The appellant is therefore, sentenced to the period already undergone.”
The appellants represented by AOR Smarhar Singh and advocates Shweta Kumari, Pankaj Prakash, Mohd Asim, Manoj Kumar, and Vikas Chopra.
The respondent represented by AOR Azmat Hayat Amanullah and advocate Rebecca Mishra.