Daya Ram & Ors. v. State of Haryana

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1590 of 2011)Decided 2 Jul 2015
Criminal Appeal No. 1590 of 2011
Justice Prafulla C. Pant · Justice Amitava Roy

Background

Following a prior altercation and threats, the appellants were convicted of murdering two brothers in a field, based substantially on the testimony of a single eyewitness (PW 3), who was himself the brother of the deceased and the original complainant. The trial court sentenced the appellants to life imprisonment, and the Punjab and Haryana High Court upheld both the conviction and a related criminal revision petition filed by the complainant against the acquittal of three co-accused. The appellants challenged their conviction before the Supreme Court, questioning the reliability of the eyewitness given his unusual conduct of hiding rather than intervening, and arguing the medical evidence and recovery of weapons did not sufficiently corroborate the prosecution's case.

Decision Breakdown

The Supreme Court held that the eyewitness's account was graphic, coherent, and consistent with the medical (post-mortem) evidence and the recovery of weapons on the appellants' own disclosure statements, and found no reason to disbelieve him merely because he hid rather than intervened: the Court reasoned that individuals react unpredictably when confronted with a sudden, life-threatening attack, and fear-driven inaction does not automatically discredit an otherwise credible witness. Weighing the totality of the evidence, the Court agreed with the concurrent findings of the trial court and High Court that the appellants' guilt was established beyond reasonable doubt. It accordingly affirmed the conviction and sentence and dismissed the appeal as lacking merit.

Lesson Learnt

A sole eyewitness's testimony can sustain a murder conviction if it is cogent and corroborated by medical and forensic evidence, and a witness's instinctive, fear-driven failure to intervene during a violent attack does not by itself make their account unreliable.

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