MAHENDRA SINGH AND ORS. versus STATE OF M.P.

MAHENDRA SINGH AND ORS. versus STATE OF M.P.

PW6's evidence was held to be wholly unreliable because contemporaneous testimony of PW3 and PW4, corroborated by defence witnesses DW3 and DW4, showed PW6 could not have witnessed the incident; medical evidence only proved homicidal death and could not corroborate PW6's claim of witnessing; motive alone is insufficient for conviction; accordingly the prosecution failed to prove guilt beyond reasonable doubt and convictions based solely on PW6 could not be sustained, leading to acquittal of the appellants.

Parties
Appellants: Mahendra Singh and Ors.; Respondent: State of M.P.
Jurisdiction
India
Judgment Date
03 June 2022
Procedural Posture
Criminal Appeal / Final Judgment on Appeal by the Supreme Court Allowing the Appeals
Outcome
Appeals allowed; impugned judgments quashed and set aside; appellants acquitted.
Legal Topics
Murder, Eyewitness Testimony, Corroboration, Post Mortem Evidence, First Information Report, Motive, Acquittal
Criminal Law Indian Penal Code, 1860 Murder Eyewitness Testimony Corroboration Post Mortem Evidence First Information Report Motive +1 more

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Parties

Mahendra Singh and Ors.

Appellants

State of M.P.

Respondent

Procedural Posture

Criminal Appeal / Final Judgment on Appeal by the Supreme Court Allowing the Appeals

Legal Issues

  1. 1 Whether conviction can be sustained on the sole testimony of an eyewitness (PW6) who is claimed to be unreliable
  2. 2 Whether medical/post-mortem evidence can be used to corroborate an eyewitness's claim of having witnessed the incident
  3. 3 Whether proof of motive suffices to sustain conviction

Ratio Decidendi

PW6's evidence was held to be wholly unreliable because contemporaneous testimony of PW3 and PW4, corroborated by defence witnesses DW3 and DW4, showed PW6 could not have witnessed the incident; medical evidence only proved homicidal death and could not corroborate PW6's claim of witnessing; motive alone is insufficient for conviction; accordingly the prosecution failed to prove guilt beyond reasonable doubt and convictions based solely on PW6 could not be sustained, leading to acquittal of the appellants.

Court Disposition

Appeals allowed; impugned judgments quashed and set aside; appellants acquitted.

Orders

  • Appeals allowed.
  • The impugned Division Bench judgment dated 6 August 2019 and the Sessions Trial judgment dated 18 April 2000 are quashed and set aside.