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M. Nageswara Reddy vs. The State of Andhra Pradesh & Ors.

Criminal Appeal · 2022 INSC 266Decided 7 Mar 2022
Criminal Appeal Nos. 72-73 of 2022
M.R. Shah · B.V. Nagarathna

Background

In 2007, the complainant's brother was hacked to death by an armed group near Kurnool, and several others, including the complainant and the vehicle's driver, were injured in the same attack. The trial court convicted three of the eleven accused (the alleged main assailants) for murder and rioting, sentencing them to life imprisonment, while acquitting the remaining eight accused for lack of evidence. The Andhra Pradesh High Court went further and acquitted even the three convicted accused, mainly doubting the FIR's credibility over an alleged time interpolation and treating the eyewitnesses as "interested" or "planted" because they were relatives of the deceased.

Decision Breakdown

The Supreme Court upheld the acquittal of the eight accused against whom the evidence was genuinely weak, since courts below had concurrently found them not guilty. However, it held that the High Court erred in acquitting the three main accused: being relatives of the deceased does not automatically make eyewitnesses "interested" or unreliable, and minor inconsistencies (like a seven-hour delay in sending the FIR to the Magistrate, still within the 24-hour legal limit) were not the kind of material contradictions that should undo consistent eyewitness and injured-eyewitness testimony. The Court restored the trial court's conviction and life sentence for the three main accused and directed them to surrender within four weeks.

Lesson Learnt

A witness's relationship to the victim does not by itself make their testimony unreliable, and small procedural delays or inconsistencies that don't go to the heart of the incident should not be used to overturn a conviction that rests on credible, consistent eyewitness evidence.

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

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