Kamal Prasad & Ors. vs State of M.P. (Now Chhattisgarh)
Background
In 1988, a group of 11 men attacked Chetram and his son Kapildeo with country-made bombs and sticks/axes ("lathis and tabbal") as Chetram was taking his son to hospital; both victims died. Nine of the original accused were convicted by the Trial Court and their convictions were upheld by the High Court. Three of them (Kamal Prasad, Sher Singh, and Bhavdas) appealed to the Supreme Court, arguing the FIR was delayed and suspicious, the eyewitnesses' accounts were contradictory, the deceased had enemies of his own who could have been responsible, and that they were elsewhere at the time (alibi).
Decision Breakdown
The Supreme Court rejected all four defence arguments. It found the roughly two-hour delay in filing the FIR was adequately explained, the main witness was himself injured and hid in fear before reporting the incident, and was not indicative of fabrication. The alibi evidence (from defence witnesses claiming the accused were elsewhere) was uncorroborated and did not meet the strict standard required to prove an alibi, especially against three consistent, credible eyewitnesses who were not close relatives of the deceased. The Court found the eyewitness testimonies consistent on all material facts (presence of the accused, weapons used, and the killing itself), and held that the deceased's alleged criminal history, even if true, was irrelevant to whether the accused committed the murder. The convictions and sentences were upheld, and the appellants' bail was cancelled with a direction to surrender.
Lesson Learnt
Courts will not let a defendant's claim that "someone else had a motive" or a technical challenge over FIR delay override strong, consistent eyewitness testimony; and an alibi defence must be proven with solid, corroborated evidence: a bare claim of being elsewhere, unsupported by independent proof, will not create reasonable doubt.