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Dadu @ Ankush vs. State of Madhya Pradesh

Not available · 2025 INSC 1395Decided 8 Dec 2025
Not available
Justice Dipankar Datta · Justice Augustine George Masih

Background

Two appellants, Dadu @ Ankush and Ankit, were convicted by a Special Court in Madhya Pradesh (one under Section 323 IPC (voluntarily causing hurt), and the other under Sections 354 and 323 IPC along with Section 3(1)(xi) of the SC/ST Act) after a young woman complained that they had teased her, caught her by the neck/dupatta, and beaten her brother when he came to her rescue. The High Court of Madhya Pradesh dismissed their appeal against conviction, and they approached the Supreme Court by special leave.

Decision Breakdown

The Supreme Court closely re-examined the evidence and found major inconsistencies between the written FIR, the victim's court testimony, and her brother's testimony, including unexplained absence of any independent eyewitness despite the brother claiming "many people" saw the incident, medical evidence suggesting the injuries were consistent with a fall rather than an assault, and a hostile witness (PW-4) whose testimony that a scuffle broke out over stepped-on feet at a crowded festival was wrongly disregarded by the High Court merely because he turned hostile. The Court held that the discrepancies rendered the prosecution's story unbelievable, that there was no evidence the caste-based intent required under the SC/ST Act was actually proved, and that the defence had plausibly shown a scuffle unrelated to caste animus. The conviction and sentence of both appellants were set aside and the appeal was allowed.

Lesson Learnt

A criminal conviction cannot rest on a complainant's story alone when it is materially inconsistent with medical evidence and unsupported by any independent witness. Courts must also give proper weight to a hostile witness's testimony rather than discard it outright, and offences under special statutes like the SC/ST Act require the specific caste-based intent to be actually proved, not merely assumed.

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

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