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Postman Vengaisamy & Ors. v. State rep. by Inspector of Police & Ors.

Criminal Appeal · 2019 INSC 802Decided 24 Jul 2019
Criminal Appeal No. 1234 of 2010
Justice L. Nageswara Rao · Justice Hemant Gupta

Background

Following a dispute over money owed for goats sold to the deceased, a group of men led by one of the accused attacked and killed the victim with swords and injured two eyewitnesses who were with him, after an earlier related altercation days before. The trial court convicted several of the accused for murder and rioting, and the High Court largely upheld the convictions. The surviving appellants (three of the original accused, the others having already served their sentences) challenged their convictions before the Supreme Court, arguing the eyewitnesses were unreliable, planted, and contradictory.

Decision Breakdown

The Supreme Court held that the two injured eyewitnesses' testimony was corroborated by contemporaneous medical evidence (injury certificates and the post-mortem report) and that minor contradictions, attributable to the passage of time and differing perception, did not undermine their overall credibility. The Court distinguished the precedents cited by the defence, noting that unlike those cases, the credibility of the witnesses here was never genuinely in doubt and a clear motive existed from an earlier altercation. It reaffirmed that the maxim "falsus in uno, falsus in omnibus" (false in one thing, false in everything) has no application in Indian law, so an unproven part of a witness's testimony does not require rejecting the whole of it. Finding no error in the concurrent findings of the trial court and High Court, the Supreme Court dismissed the appeal, while granting the appellants three months to surrender before the trial court.

Lesson Learnt

Minor inconsistencies in a witness's account, especially after a long passage of time, do not automatically destroy their credibility if the core of their testimony is corroborated by independent evidence like medical records: Indian courts do not apply an all-or-nothing rule to witness testimony.

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

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