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Karan Singh vs The State of Uttar Pradesh & Ors.

Criminal Appeal · 2022 INSC 253Decided 2 Mar 2022
Criminal Appeal No. 327 of 2022
Indira Banerjee · V. Ramasubramanian

Background

In 1980, a dispute over unpaid money for a buffalo led to a violent confrontation in a UP village: the debtor Rajkumar Singh arrived with several armed associates, including the appellant Karan Singh, and when the creditor Brahmapal Singh asked for his money, Rajkumar Singh shot him dead, after which his associates also allegedly opened fire, injuring a bystander (Mahender Singh) as well. The Trial Court convicted the appellant and other accused of murder and related offences in 1983, sentencing him to life imprisonment; the Allahabad High Court dismissed his appeal in 2018. By the time the case reached the Supreme Court, five of the six convicted accused had died, leaving Karan Singh as the sole surviving appellant.

Decision Breakdown

The appellant argued that no eyewitness had specifically named him as firing, that the injured witness Mahender Singh did not identify him at the spot, that no weapon or spent cartridges linked to him were recovered, and that all injuries were shown medically to be from pellet/gunshot wounds consistent only with certain weapons. The Supreme Court held that two eyewitnesses (PW2 and PW3) had clearly testified that the appellant was present at the scene armed with a rifle and that all the accused, including him, had opened fire after the first shot by Rajkumar Singh, and that the prosecution needs to prove guilt beyond reasonable doubt, not beyond every conceivable doubt. It found the minor discrepancies pointed out (such as one injured witness not specifically naming the appellant) did not undermine the substantial corroborated eyewitness and medical evidence, relying on a line of precedent holding that minor discrepancies not going to the heart of the matter cannot be used to discredit otherwise credible testimony. Finding no ground to interfere with the concurrent findings of guilt by the Trial Court and High Court, and holding that the long delay in the litigation or the deaths of co-accused during the appeal could not itself be grounds for acquittal, the Court dismissed the appeal.

Lesson Learnt

A criminal conviction based on corroborated eyewitness testimony will not be overturned merely because one witness fails to specifically name an accused or because there are minor, non-material inconsistencies in the evidence. Courts look at whether the evidence as a whole carries a "ring of truth," and the standard is proof beyond reasonable doubt, not proof beyond every possible doubt.

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

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