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Siba Nial @ Trilochan v. The State of Odisha

Criminal Appeal · 2025 INSC 206Decided 11 Feb 2025
Crl.A. No.-000674-000674 - 2025 (arising from SLP(Crl.) No. 9244 of 2024)
Chief Justice · Justice Sanjay Kumar

Background

Siba Nial @ Trilochan was convicted for the murder of a married couple, Dhaneswar Kata and his wife Nirupama, who were shot dead while sleeping on the terrace of their home in Odisha in 2013 - a killing the prosecution linked to opposition over the couple's inter-caste marriage and a property dispute. Neither the informant nor the other family members who were present on the terrace that night could identify the attackers, and the appellant was arrested only nine days after the incident, based mainly on the testimony of two neighbours who claimed to have seen him near the scene. The High Court had upheld his conviction.

Decision Breakdown

The Supreme Court found the prosecution's case riddled with serious gaps: the two neighbour-witnesses stayed silent for nine days despite the shock the killings would have caused in the locality, none of the family members present at the scene named any culprit, and the forensic and ballistic evidence was ambiguous and did not clearly support the version given by the witnesses - the postmortem suggested the fatal shot was not fired at close range, contrary to the eyewitnesses' account. Given these unresolved doubts and contradictions, the Court held that the appellant's guilt had not been proved beyond reasonable doubt, set aside the conviction, and ordered his release from custody.

Lesson Learnt

A criminal conviction cannot stand on witness testimony that is inconsistent with the forensic evidence or marred by unexplained, prolonged silence from key witnesses - the prosecution must prove guilt beyond reasonable doubt on the whole of the evidence, not just on some of it.

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

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