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Guman Singh v. State of Rajasthan

Criminal Appeal · 2019 INSC 685Decided 24 May 2019
Criminal Appeal No. 1475 of 2017
Justice Indira Banerjee · Justice Sanjiv Khanna

Background

The appellant, Guman Singh, was convicted of murdering Shiv Charan and attempting to murder Babu Singh in a 2009 motorcycle shooting in Rajasthan, and his conviction was upheld by the Rajasthan High Court. The case against him rested heavily on two purported eyewitnesses, the deceased's son and nephew, who claimed to have been following the victims on another motorcycle and to have seen the appellant fire the fatal shots. However, the investigating officer's own testimony showed these two witnesses were not at the scene when he arrived shortly after the shooting, and only came forward with their account roughly three hours later at the hospital.

Decision Breakdown

The Supreme Court found the two eyewitnesses' testimony unreliable, since it directly conflicted with the independent testimony of the investigating officer and another police witness, who placed the duo away from the scene at the material time; it also noted the surviving injured witness, Babu Singh, turned hostile and never identified the appellant at all. Forensic evidence was found too weak to corroborate guilt: the recovered bullets from the deceased were never sent for ballistic comparison, and the examined pistol could not be conclusively linked to the recovered bullet. Applying the Court's established framework for classifying witnesses as wholly reliable, wholly unreliable, or requiring corroboration, the Court held that even on the most generous reading these eyewitnesses' evidence needed independent corroboration that did not exist, so the prosecution failed to prove guilt beyond reasonable doubt.

Lesson Learnt

A criminal conviction cannot rest on eyewitness testimony that is directly contradicted by independent evidence (such as the investigating officer's own account of who was and wasn't at the crime scene) unless it is corroborated by reliable supporting evidence; courts must scrutinise witness credibility carefully rather than accept claimed eyewitness accounts at face value.

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

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