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Karulal & Ors. v. The State of Madhya Pradesh

Criminal Appeal · 2020 INSC 582Decided 9 Oct 2020
Criminal Appeal No. 316 of 2011
Justice N.V. Ramana · Justice Surya Kant · Justice Hrishikesh Roy

Background

Five men were convicted of murdering a farmer, Madhavji, who was attacked in his fields in Madhya Pradesh in 1993 by a group wielding axes, swords, and sticks, allegedly over a long-standing enmity between the families. The conviction rested mainly on the testimony of the deceased's son and daughter, who said they witnessed the attack, along with a third, unrelated eyewitness, and was upheld by the Madhya Pradesh High Court. The appellants argued the witnesses should be disbelieved because they were closely related to the victim and because the defense claimed the injuries resulted from an accidental fall, not an assault.

Decision Breakdown

The Supreme Court upheld the conviction, reaffirming the well-established principle that the testimony of relatives of a victim is not automatically suspect: close relatives are, if anything, unlikely to falsely implicate an innocent person while letting the real culprit go free. The Court found the eyewitness accounts of the son and daughter were corroborated by an independent eyewitness and by medical evidence showing injuries consistent with the described assault, while the defense's "accidental fall" theory was unsupported by any medical opinion that specifically attributed the injuries to such a fall. Concluding that the trial court and High Court had correctly and carefully evaluated the evidence, the Supreme Court dismissed the appeal and upheld the life sentence.

Lesson Learnt

Being related to a crime victim does not by itself make a witness's testimony unreliable: courts weigh relatives' evidence on its own merits and corroboration, rather than discarding it solely because of family connection.

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

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