Jagdish & Another v. The State of Haryana
Background
Of thirteen original accused in a 1995 mob assault that killed a man following a long-running personal feud between two families, the two appellants were convicted of murder along with one other person (the third was acquitted on appeal) while the rest were acquitted at trial itself. The conviction rested essentially on the testimony of a single eyewitness, the deceased's sister, who was the only person present willing to identify the specific role of each attacker; her husband (claimed to be another eyewitness) was found by the trial court not to have actually been present. The appellants challenged their conviction before the Supreme Court, questioning the reliability of this solitary witness.
Decision Breakdown
The Supreme Court found the eyewitness's account riddled with improbabilities, including an unexplained six-hour delay in lodging the FIR, the implausibility of two women going alone to a police station at 3 a.m. while armed male relatives stayed home out of claimed fear, and a mismatch between the eleven injuries (including sharp-weapon wounds) found on the deceased's body and the claim that only two men armed with lathis had done the assault. The Court reiterated that a conviction can rest on a solitary eyewitness only if that testimony is wholly reliable and subjected to heightened scrutiny, especially where pre-existing enmity between the families raised a real possibility of false implication. Concluding that the witness's evidence was not safe to rely upon and that the High Court had erred in treating the husband as a genuine eyewitness, the Supreme Court set aside the conviction, allowed the appeal, and acquitted the two appellants.
Lesson Learnt
A criminal conviction can legally rest on the testimony of just one eyewitness, but courts must scrutinise that evidence much more carefully when there is a pre-existing family feud, unexplained delays in reporting the crime, or a mismatch between the alleged weapons and the actual injuries: any real possibility of false implication must be resolved in the accused's favour.