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Imrat Singh & Ors. v. The State of Madhya Pradesh

Criminal Appeal · 2019 INSC 1190Decided 24 Oct 2019
Criminal Appeal No. 480 of 2009
Justice Deepak Gupta · Justice Aniruddha Bose

Background

Five men were convicted of murdering one Gajraj Singh in 1994 and sentenced to life imprisonment by the Sessions Court, a conviction upheld by the Madhya Pradesh High Court. The conviction rested mainly on two eyewitnesses who claimed to have seen the accused beating the deceased, and two further witnesses who claimed to have "last seen" the deceased in the company of one of the accused. The convicted men appealed to the Supreme Court, arguing the witnesses were unreliable.

Decision Breakdown

The Supreme Court went through each prosecution witness's testimony in detail and found serious, material contradictions, about who first told the village of the death, when and how the police complaint was lodged, whether a site plan was genuine, and what was actually said at the scene, that cast real doubt on the witnesses' truthfulness. It noted that several people who should have corroborated the witnesses' accounts (including those first informed of the incident and certain police officials) were never produced in court, and that the investigation appeared unfair. Given these unresolved doubts, the Court held that the benefit of the doubt must go to the accused, set aside the convictions of both lower courts, and acquitted all the accused.

Lesson Learnt

A criminal conviction cannot stand merely because eyewitnesses agree on the bare core of an incident: if their accounts are riddled with serious, unexplained contradictions about the surrounding facts, and key corroborating witnesses are never brought to court, the accused must be given the benefit of the doubt.

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

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