Amar Singh v. The State (NCT of Delhi)

Criminal Appeal · 2020 INSC 587Decided 12 Oct 2020
Criminal Appeal No. 335 of 2015
Justice Sanjay Kishan Kaul · Justice Aniruddha Bose · Justice Krishna Murari

Background

In 1990, Devinder Singh was fatally attacked near a Delhi market and died shortly after. Two of his brothers who were allegedly walking with him at the time said they witnessed three men, including the appellants, assaulting him with hockey sticks and a knife. Based largely on the testimony of one brother who was the only one of the three eyewitnesses whose account was not disowned at trial, the trial court and Delhi High Court convicted the appellants of murder and sentenced them to life imprisonment.

Decision Breakdown

The Supreme Court overturned the conviction, finding the sole surviving eyewitness's account riddled with inconsistencies and "unnatural conduct": notably, that the two brothers who claimed to be present made no attempt to save their sibling from attackers armed only with hockey sticks and a knife, and did not seek nearby medical help despite a clinic being close by. The Court also noted a serious discrepancy in the hospital's medical-legal record of the deceased's identity and companions, and that the post-mortem injuries (15 wounds) were difficult to reconcile with the eyewitness's claim that the assault lasted only five minutes. Because the prosecution's case rested on a single, uncorroborated eyewitness whose reliability was seriously undermined, the Court held the guilt had not been proved beyond reasonable doubt and acquitted the appellants, giving them the benefit of the doubt.

Lesson Learnt

A criminal conviction cannot rest safely on a single eyewitness whose account conflicts with ordinary human behavior and contemporaneous records: courts will set aside even a concurrent finding of guilt by two lower courts where the core evidence does not withstand scrutiny.

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