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Adalat Yadav Etc. v. The State of Bihar

Criminal Appeal · 2026 INSC 403Decided 22 Apr 2026
Crl.A. No.-001788-001789 - 2019
Justice Sanjay Karol · Justice Nongmeikapam Kotiswar Singh · Justice Vipul M. Pancholi

Background

A father and son, Adalat Yadav and Anirudh Yadav, were convicted of murder and related offences for shooting dead Ram Sharan Yadav and firing on his brother (the complainant) and others in Begusarai, Bihar, in 2008. The prosecution's case was that the killing was retaliation for the deceased having testified as a witness in an earlier murder case, and that there was long-standing enmity between the families going back to a 2003 attack. Both the Trial Court and the Patna High Court's Division Bench upheld the conviction and life sentence, and the two convicts appealed to the Supreme Court challenging the reliability of the eyewitness testimony, delay in lodging the FIR, an alleged conflict between eyewitness and medical evidence, and the absence of independent (non-family) witnesses.

Decision Breakdown

The Supreme Court dismissed the appeals and upheld the convictions. It held that reliance on the principal eyewitness (the injured complainant, PW-5) was proper since his testimony withstood cross-examination, was consistent with the medical evidence about the location of the fatal gunshot wound, and as an injured eyewitness his account carried greater weight. The Court found no fatal inconsistency between the eyewitness and medical testimony, and held that the delay in filing the FIR did not by itself undermine the prosecution's case since it must be assessed against the overall facts, especially where witnesses may reasonably hesitate to come forward against a locally powerful and feared accused. It also held that the absence of independent (non-family) witnesses was not fatal, given the realistic societal reluctance of ordinary people to get involved in violent disputes, especially where the victim had been killed for testifying as a witness in another case. The conviction under Section 307 IPC for the second appellant was upheld as the evidence showed he had fired with intent to kill, and it was only fortuitous that his bullet did not prove fatal.

Lesson Learnt

Courts will not automatically discount an eyewitness's testimony merely because of delay in filing the FIR or the absence of independent bystander witnesses: such factors must be weighed against the practical realities of each case, including witness fear in cases involving locally powerful accused persons; an injured eyewitness whose account is internally consistent and matches medical evidence can, by itself, sustain a conviction.

Official source (sci.gov.in)View Judgment (PDF)

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