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Santosh Singh v. The State of Madhya Pradesh

Criminal Appeal · 2026 INSC 972Decided 8 Sept 2026
Criminal Appeal Nos. 1303-1305 of 2022 with Criminal Appeal No. 1306 of 2022
Justice J.B. Pardiwala · Justice K. Vinod Chandran

Background

Seventeen people were accused of ambushing and shooting dead a man while injuring his brother (the eyewitness/de-facto complainant, referred to as PW1), following a prior altercation and a long-standing family enmity. The Trial Court convicted four of the accused (A1, A6, A12 and A13) and acquitted the rest; the High Court, in cross-appeals, upheld only A1's conviction while acquitting A6, A12 and A13, and separately confirmed the acquittal of the other accused. The injured brother/complainant filed appeals before the Supreme Court challenging all these acquittals.

Decision Breakdown

The Supreme Court examined the eyewitness testimony and medical evidence in detail, including the postmortem findings on the bullet's trajectory, and rejected the High Court's reasoning that acquitted A6 on the theory that a person restraining the victim would himself have been injured. It restored the conviction of A6 and A12, holding their roles (physically holding down the victim, and exhorting the shooter to kill) were clearly and consistently established by credible eyewitnesses, applying the principle that Indian courts must "separate the grain from the chaff" rather than reject an entire prosecution case because some accused were falsely implicated (falsus in uno, falsus in omnibus does not apply in India). However, it sustained the acquittal of A13, finding his alibi evidence undisplaced, and also upheld the acquittal of the remaining accused, since the testimony against them contained only vague, omnibus allegations of presence without any specific role. A6 and A12 were given two weeks to surrender to serve their restored sentences.

Lesson Learnt

Indian courts can accept the credible part of a witness's testimony implicating some accused while rejecting the same witness's vague or exaggerated claims against others. A prosecution case is not automatically discredited in its entirety merely because it contains some over-implication; but a conviction still requires evidence of each individual's specific role, not just presence in a crowd.

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

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