Punimati & Anr. vs The State of Chhattisgarh & Ors.

Not available · 2025 INSC 1454Decided 18 Dec 2025
Not available
Justice Prashant Kumar Mishra · Justice Vipul M. Pancholi

Background

In 2010, in a Chhattisgarh village, a group of persons allegedly beat one Goreylal with sticks and stones over a caste-related dispute, and he died. His mother, who arrived at the scene after being told of the assault by her granddaughter, was the main eyewitness. The trial court convicted seven accused (including the appellants) under Section 302 read with Sections 148/149 IPC and sentenced them to life imprisonment; the Chhattisgarh High Court upheld the conviction. The accused appealed to the Supreme Court, arguing that the mother's testimony was contradictory, the granddaughter who allegedly witnessed the assault was never examined, and other independent witnesses had turned hostile.

Decision Breakdown

The Supreme Court found material contradictions in the mother's (PW-4's) testimony. She admitted she arrived only after her son was already injured and could not say which accused's stick or stone caused which injury, and the person who allegedly witnessed the actual assault (the granddaughter) was never produced as a witness. Independent witnesses to the seizure of weapons turned hostile, undermining the recovery evidence. The post-mortem doctor could not attribute specific wounds to specific weapons, and it was medically implausible that three separate incise wounds came from the single stone seized. Given these gaps, the Court held the prosecution had failed to prove guilt beyond reasonable doubt, set aside the conviction and sentence, allowed the appeals, and discharged the bail bonds of the appellants (who had already been released on bail earlier in 2025).

Lesson Learnt

A criminal conviction cannot rest on an eyewitness account riddled with contradictions and unsupported by corroborating evidence. Where the person who actually claims to have identified the assault was never examined and independent witnesses turn hostile, the benefit of the doubt must go to the accused, however serious the crime.

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