Shahid Khan v. State of Rajasthan
Background
One Ashok Kumar, who managed a stone-cutting factory and held a share in a toll-tax royalty contract, was murdered by a group of assailants in Jhalawar, Rajasthan, allegedly because he had assisted a man accused of an earlier, unrelated murder. The Sessions Court convicted four of the five accused under Sections 148 and 302/149 IPC (rioting and murder with common object), relying heavily on two purported eyewitnesses who claimed to have seen the attack from inside the factory before hiding out of fear. The Rajasthan High Court upheld the conviction, and three of the convicted men appealed to the Supreme Court.
Decision Breakdown
The Supreme Court closely scrutinized the two key eyewitnesses and found their account unbelievable: they were from a city 150 km away, failed to assist in rescuing the victim or inform the hospital or police despite being present, and one was a known history-sheeter with prior cases against him. Their statements were also recorded only three days after the incident with no explanation for the delay, which the Court held cast serious doubt on whether they were genuine eyewitnesses at all, especially since no independent evidence corroborated their account. Concluding that the prosecution had not proved its case beyond reasonable doubt and that the High Court had failed to properly re-examine the evidence, the Supreme Court allowed the appeals, set aside the conviction and sentence, and ordered the appellants' bail bonds discharged.
Lesson Learnt
A criminal conviction cannot rest on eyewitness testimony that is inherently implausible or unexplainably delayed: courts must closely test witnesses' conduct and credibility against ordinary human behaviour, and unexplained gaps (like a multi-day delay in recording statements) can be enough to collapse a conviction on appeal.