Prabhash Kumar Singh v. The State of Bihar (Now Jharkhand)
Background
The appellant was convicted of murdering a man named Ashok Rewani by shooting him during a confrontation at a tea stall in Bokaro district, Jharkhand, in 1993. Both the Trial Court and the High Court of Jharkhand had found him guilty based on eyewitness testimony and medical/post-mortem evidence, sentencing him to life imprisonment (a co-accused, his father, had also been convicted but died before this appeal was decided, so that part of the appeal abated). He appealed to the Supreme Court arguing the medical evidence did not conclusively match a close-range gunshot and that eyewitnesses could not have clearly seen the incident at night.
Decision Breakdown
The Supreme Court examined the medical evidence in detail, including the post-mortem surgeon's testimony, and found no real contradiction between the injuries and the prosecution's gunshot theory: the surgeon had plausibly explained that a fractured rib could result from a fall rather than undermining the firearm cause of death, and that digested food found in the stomach did not disprove the time of death given normal post-mortem digestion patterns. The Court also rejected the "poor visibility" defense since the incident occurred in a lit, populated area near tea shops. Finding the eyewitness accounts of two witnesses credible and unshaken in cross-examination, and noting that failure to recover the weapon or bullet did not defeat the prosecution's case, the Court dismissed the appeal and upheld the conviction and life sentence, cancelling the appellant's bail and directing him to surrender within four weeks.
Lesson Learnt
A criminal conviction can stand on credible, consistent eyewitness testimony corroborated by medical evidence, even without recovery of the physical weapon: minor technical gaps in forensic reconstruction do not automatically create reasonable doubt if the core eyewitness account survives cross-examination.