Mitesh @ T.V. Vaghela v. The State of Gujarat
Background
The appellant was convicted of murder under Section 302 IPC by a Sessions Court in Ahmedabad and sentenced to life imprisonment, after a quarrel with the deceased over a thrown cigarette allegedly led him to fatally assault the victim. The Gujarat High Court upheld the conviction on appeal. The appellant then approached the Supreme Court, arguing that since many prosecution witnesses (including panch and some eyewitnesses) had turned hostile, he deserved the benefit of the doubt.
Decision Breakdown
The Supreme Court examined the testimony of the complainant (PW-1) and another eyewitness (PW-12) and found their accounts consistent, credible, and unshaken in cross-examination, sufficient to establish the appellant's guilt beyond reasonable doubt. It reaffirmed the settled principle that criminal convictions turn on the quality, not quantity, of evidence, even a solitary credible witness can sustain a conviction, relying on precedent including Namdeo v. State of Maharashtra. Since the hostility of other witnesses did not undermine the reliable core testimony, the Court found no infirmity in the concurrent findings of the Trial Court and High Court and dismissed the appeal. However, considering the appellant had already served a substantial part of his sentence, the Court granted him liberty to seek remission under applicable policy, to be considered expeditiously.
Lesson Learnt
In Indian criminal trials, a conviction can validly rest on the testimony of even one credible, unshaken witness: the number of witnesses who turn hostile does not automatically create reasonable doubt if the core evidence is reliable and consistent.