Balaram vs. The State of Madhya Pradesh
Background
A group of villagers travelling on a bullock cart were stopped and fired upon by several men, resulting in the death of a young man named Ashok and injury to his mother. The appellant, Balaram, along with others (including one Uma Charan), was accused of firing shots. At trial, four of the six accused were acquitted, but Balaram and one other man (who later died during the appeal, abating his case) were convicted of murder and related offences, a conviction upheld by the Madhya Pradesh High Court.
Decision Breakdown
The Supreme Court found that the two main eyewitnesses, the mother and father of the deceased, had given testimony that the trial court itself had disbelieved when it came to the accused Uma Charan (acquitting him on the same evidence), yet had inconsistently relied upon the same evidence to convict Balaram. Applying the settled principle that witnesses are either wholly reliable, wholly unreliable, or partly reliable, the Court held that once these witnesses were found unreliable regarding one accused based on identical testimony, they could not selectively be believed regarding another. It held that the trial court could not apply a different standard to different accused persons based on the very same evidence, and that previous enmity between the families (offered as a motive) could equally suggest false implication. The Court set aside the conviction and acquitted Balaram, directing his release if not required in any other case.
Lesson Learnt
Courts cannot pick and choose parts of the same witness testimony to convict one accused while disbelieving that very testimony to acquit another accused of an identical charge: such inconsistency renders a conviction unsafe and warrants acquittal on appeal.