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Nagaraj Reddy vs. The State of Tamil Nadu (Criminal Appeal No. 886 of 2023)

Criminal Appeal · 2023 INSC 269Decided 21 Mar 2023
Criminal Appeal No. 886 of 2023
B.R. Gavai · Vikram Nath

Background

In 2004, in a village in Krishnagiri district, tensions between two communities over a compound-wall construction contract led to the murder of one Rajappa, who was hacked to death with sickles while on his way to depose in an unrelated court case. Thirteen people were accused; the trial court convicted the appellant (accused No. 1) and one other man of murder based mainly on the eyewitness testimony of the deceased's brother, Narayanappa (PW-1), while acquitting the rest. On appeal, the High Court acquitted the other convicted man (accused No. 3) because the evidence about the timing of his arrest didn't match the prosecution's case, but upheld the appellant's conviction, reasoning his own conduct (absconding, then surrendering) distinguished his case.

Decision Breakdown

The Supreme Court found the High Court's reasoning for treating the two convicted men differently to be "totally perfunctory," since both convictions rested solely on the same witness, Narayanappa (PW-1), who was undisputedly an "interested witness" as the victim's brother, with an admitted prior enmity with the accused. Applying the principle that uncorroborated testimony of such a witness demands caution, and noting the trial court itself had already found PW-1 unreliable regarding ten of the thirteen accused, the Court held the appellant's conviction could not stand on this uncorroborated evidence alone. The appeal was allowed, the conviction quashed, and the appellant ordered released.

Lesson Learnt

A criminal conviction cannot rest safely on the testimony of a single interested witness (such as a close relative of the victim with a known prior enmity with the accused) without independent corroboration, especially where that same witness's evidence has already been found unreliable in relation to other co-accused in the very same case.

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

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