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Arun v. State of Madhya Pradesh

Criminal Appeal · 2025 INSC 406Decided 27 Mar 2025
Crl.A. No.-001549-001549 - 2025
Chief Justice Sanjiv Khanna · Justice Sanjay Kumar · Justice K.V. Viswanathan

Background

Mohan Singh was killed in 2009 near Indore, and five men (who had an existing land-dispute enmity with his family) were tried for his murder. The trial court convicted all five and sentenced them to life imprisonment; the Madhya Pradesh High Court later acquitted one of them but upheld the conviction of the remaining four (Arun, Radheshyam, Narendra, and Ramlal), who then appealed to the Supreme Court by special leave. The prosecution's case rested almost entirely on the oral testimony of the victim's father, wife, brother, and young nephew, who claimed to have witnessed the attack.

Decision Breakdown

The Supreme Court acquitted all four remaining appellants, finding the prosecution's eyewitness evidence "completely untrustworthy and specious." It highlighted that the original FIR named only one accused and an unidentified man, while the same witnesses later gave the trial court elaborate, embellished accounts naming all five accused with specific acts: a stark contradiction the investigating officer himself confirmed was absent from their earlier statements to police. The timelines given by the witnesses (including a 6-7 year old child witness) for when the victim could have reached the crime scene did not add up and were mutually inconsistent. The medical evidence was also undermined: the doctor first said the fatal wound was a gunshot wound but conceded in cross-examination it was actually caused by a stabbing weapon, and no bullet was ever recovered from the body, making the recovered pistol irrelevant. Applying the principle that convictions cannot rest on doubtful, embellished testimony, and giving the accused the benefit of the doubt, the Court set aside both lower court judgments and ordered the release of all appellants.

Lesson Learnt

A conviction cannot stand on witness testimony that dramatically expands or changes from what was originally told to police in the FIR. Courts will scrutinize such embellishments carefully, especially from an accused's declared enemies, and inconsistent timelines or medical contradictions can be enough to create reasonable doubt and overturn even a life sentence.

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

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