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Parvat Singh & Ors. v. The State of Madhya Pradesh

Criminal Appeal · 2020 INSC 244Decided 2 Mar 2020
Criminal Appeal No. 374 of 2020
Justice Ashok Bhushan · Justice M.R. Shah

Background

Four men were convicted of murdering a young man in a pre-dawn attack at a cattle shed, along with a fifth accused (tried separately). The conviction rested entirely on the testimony of the victim's mother, who said she identified the attackers by torchlight and by voice. Both the trial court and the Madhya Pradesh High Court upheld the conviction of all four appellants under Section 302 read with Section 149 IPC (murder with common object).

Decision Breakdown

The Supreme Court scrutinised the mother's testimony closely and found it riddled with contradictions and improvements compared to her original police statement: for instance, she added new details about a chimney light and specific accused physically restraining the victim, details she had not mentioned earlier, and no torch was ever recovered. The High Court had also wrongly relied on her inadmissible police statement to conclude the accused carried weapons. Because no independent witness supported her account and there was a prior dispute between the families (raising a risk of false implication), the Court held it unsafe to convict on her testimony alone and gave the four appellants the benefit of the doubt, distinguishing their case from the fifth accused (already convicted separately, where physical evidence like a recovered weapon supported guilt).

Lesson Learnt

A conviction can rest on a single eyewitness, but only if that witness's account is consistent and free of material contradictions: courts will not uphold a conviction built on a story that keeps changing in material ways between the police statement and courtroom testimony.

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

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