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Chunthuram v. The State of Chhattisgarh

Criminal Appeal · 2020 INSC 616Decided 29 Oct 2020
Criminal Appeal No. 1392 of 2011
Justice Sanjay Kishan Kaul · Justice Krishna Murari · Justice Hrishikesh Roy

Background

In 2001, a man named Laxman was found dead near his village in Chhattisgarh, allegedly killed by the appellant Chunthuram and a co-accused over a prior land dispute, with a motive also linked to an earlier murder case involving the families. The trial court convicted both men, but the Chhattisgarh High Court acquitted the co-accused while upholding Chunthuram's conviction, relying on the testimony of one eyewitness said to have seen the assault, corroborated by a Test Identification Parade and recovery of items of clothing.

Decision Breakdown

The Supreme Court found serious flaws undermining the conviction: the weapons recovered were never actually forensically linked to the crime, a key chemical-analyst report was missing from the record, and the Test Identification Parade was conducted improperly with police present and contained factual inconsistencies about the clothing shown to the witness. Most critically, the sole eyewitness admitted to poor eyesight (unable to see beyond a couple of feet), poor hearing, and was positioned farther from the scene than another witness who heard nothing, and like the eyewitnesses in the companion case (Amar Singh, also decided that month), he behaved unnaturally by taking no steps to report the crime despite knowing the victim. With the eyewitness testimony unreliable and the stated motive stale (the underlying land dispute had already been settled), the Court held guilt had not been proved beyond reasonable doubt and acquitted the appellant.

Lesson Learnt

A conviction cannot stand on an eyewitness identification that is undermined by the witness's own physical limitations (such as poor eyesight or hearing) and by identification procedures that don't follow proper safeguards, like keeping police away from identification parades.

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

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