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Ranjeet Singh vs. State of Chhattisgarh (2023 INSC 636)

Diary No. · 2023 INSC 636Decided 13 Jul 2023
Diary No. 25041 of 2021
Sanjiv Khanna · Bela M. Trivedi as the bench

Background

The appellant was convicted of murdering a man found dead with head injuries near a forest in Chhattisgarh in 2010, based on the testimony of three child witnesses (two sisters and their cousin, all closely related to the deceased's family) who claimed to have seen the killing. The initial FIR, however, did not name any suspect and made no mention of these children having witnessed anything: that account emerged only eight to nine days later. The trial court convicted the appellant under Section 302 IPC and sentenced him to life imprisonment, and the Chhattisgarh High Court upheld the conviction.

Decision Breakdown

The Supreme Court found the conviction unsafe, holding that the three child witnesses' delayed, nine-day-late account: combined with their close family relationship to the complainant and other prosecution witnesses, and internal contradictions (such as a grandmother's testimony that she never allowed the children to go into the forest for wood, contradicting the stated reason they were even present): cast grave doubt on their reliability as eyewitnesses. The Court also found the prosecution's alternative theories weak: the alleged motive (a minor quarrel two to three months earlier) and the claim that the appellant had absconded were both inconsistent or unsupported by the investigating officer's own testimony. With the eyewitness accounts discredited and no other reliable evidence establishing guilt, the Court set aside the conviction and ordered the appellant's immediate release, directing the prison authorities to be notified for compliance.

Lesson Learnt

A conviction cannot rest on eyewitness testimony that surfaces only after a suspicious delay and comes from witnesses closely related to the complainant, especially when it conflicts with the original police complaint and other evidence. Courts must scrutinise such testimony with particular care before allowing it to decide a person's guilt.

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

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