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Mahendra Singh & Ors. vs The State of M.P.

Criminal Appeal · 2022 INSC 637Decided 3 Jun 2022
Criminal Appeal No. 764 of 2021
B.R. Gavai · Hima Kohli

Background

In 1994, Bhagat Singh was allegedly attacked and killed by a group of eleven men, including the appellants, while walking home with his brother Amol Singh and another companion, Akhe Singh. Amol Singh's account, given in the FIR, was the principal evidence used to convict five of the eleven accused (including the appellants) under Sections 148 and 302 read with 149 IPC; six others were acquitted by the trial court on the same evidence. The Madhya Pradesh High Court upheld the conviction of the five, leading to this appeal.

Decision Breakdown

The Supreme Court closely scrutinised the sole eyewitness testimony of Amol Singh (P.W.6), which formed the entire basis of conviction. Defence witnesses (D.W.3 and D.W.4), corroborated by the evidence of two other prosecution witnesses (P.W.3 and P.W.4), established that Amol Singh had not actually witnessed the incident but was informed of his brother's death afterward by a third person. Applying the settled classification of witnesses into "wholly reliable," "wholly unreliable," and an intermediate category, the Court held Amol Singh's testimony fell into the "wholly unreliable" category, meaning no conviction could rest on it alone; medical evidence only proved the death was homicidal, not who committed it. The appeals were allowed, the conviction was quashed, and the appellants were acquitted and ordered released.

Lesson Learnt

A criminal conviction cannot survive on the testimony of a witness shown, through cross-examination and independent evidence, to not have actually witnessed the crime, even if other, indirect evidence (like a post-mortem report) exists; proving motive or that death occurred is not enough on its own to convict.

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

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