Benefit Of Doubt Must Prevail Where Eyewitness Testimony Is Infirm And Contradict Medical Evidence: Supreme Court Acquits Double-Murder Convict

"Sole eyewitness testimony riddled with contradictions and uncorroborated by injured witnesses cannot be the sole basis of conviction in a murder trial" – In a significant ruling on January 5, 2026, the Supreme Court of India acquitted Anjani Singh, who had been convicted for double murder and attempted murder during a village function, after finding the sole eyewitness testimony unreliable and riddled with contradictions, while all other eyewitnesses either turned hostile or stated that the incident occurred in complete darkness, making identification impossible.

A Bench of Justice Manoj Misra and Justice Joymalya Bagchi, while setting aside the judgment of the Allahabad High Court dated 05.07.2019 in Criminal Appeal No. 8133 of 2007, held that serious inconsistencies in the prosecution’s case, absence of corroborative evidence, and the failure to explain key forensic gaps, made it unsafe to sustain a conviction solely on the testimony of PW-1, the informant and purported sole eyewitness.

"Prosecution Withheld Truth; Incident Did Not Occur As Alleged" – Court Slams Lack Of Forensic Coherence

The appellant, Anjani Singh, had been convicted under Sections 302, 307, and 504 of the IPC for his alleged role in a firing incident at a village drama event in Ballia, Uttar Pradesh, in October 2004, which resulted in two deaths and multiple injuries. The prosecution’s case rested heavily on the statement of PW-1, who claimed that Anjani and two co-accused indiscriminately opened fire after a minor altercation during the event.

However, the Supreme Court found that PW-1’s deposition lacked the “stellar quality” needed to convict an accused in a murder trial, especially in the face of multiple hostile witnesses, including injured eyewitnesses (PW-2, PW-3, PW-7, PW-10), who categorically stated that the electricity had gone off during the incident, making identification of the assailants impossible.

The Court observed: “Though PW-1 claimed to be the target, he suffered only superficial injuries. Others, who were not targeted, were killed from close range. This raises serious doubt on the manner of occurrence as narrated by the prosecution.”

“Unexplained Forensic Loopholes and Weapon Discrepancies Create Doubt” – Court Questions Seizure and Ballistics Evidence

The judgment lays bare the evidentiary failures of the prosecution, particularly in respect of forensic inconsistencies and weapon recovery. The rifle allegedly seized from one co-accused did not have a magazine at the time of seizure, and the magazine recovered from the crime scene did not match the seized weapon. Additionally, no empty cartridge from Anjani’s alleged country-made pistol was recovered, nor was the pistol itself found.

The Court emphasized:
“The magazine recovered from the spot could not be forensically connected to the seized rifle. The possibility of other weapons and unknown shooters cannot be ruled out.”

Further, while the prosecution claimed that the rifle was snatched by those present, none of the witnesses to the seizure supported this fact. PW-5 and PW-9, who were cited as witnesses to the snatching, denied being present during the incident, and PW-9 even stated that he had been in Punjab at the time.

Testimony of PW-1 “Inconsistent, Contradictory and Uncorroborated” – Court Deems It Unsafe For Conviction

The Court found several internal contradictions in PW-1’s testimony, including differing accounts of the assailants’ position, the firing sequence, and the handling of weapons. Importantly, PW-1 admitted that Anjani did not fire at people who were trying to snatch the rifle, nor was there any attempt to apprehend him at the scene.

The Bench observed:
“PW-1’s account varies on the basic issue of where the shots were fired from and who fired them. His version fails to convincingly establish the appellant’s specific role in the firing, especially when others have categorically stated that visibility was nil.”

Adding to the credibility concerns, PW-1 had a criminal history, including pending Arms Act charges and earlier proceedings under the Goondas/Gangsters Act, which the Court held should have prompted caution before relying solely on his statement.

“Lights Were Off, Crowd Was Large, and Eyewitnesses Turned Hostile” – Court Emphasizes Caution In Sole Eyewitness Cases

Highlighting that at least 7 other eyewitnesses turned hostile or claimed no knowledge of the shooters due to darkness, the Court held that conviction solely based on PW-1’s testimony could not be sustained.

It noted:
“All key prosecution witnesses, including those injured, deposed that lights were off during the incident. When the visibility itself is in doubt, the Court must exercise heightened caution before recording conviction.”

Further, the Court noted that the presence of more than 100 people in the crowd, and the ease with which the accused allegedly escaped, despite being weaponless after the rifle was snatched, casts doubt on the prosecution's version.

"Motive Unclear, Victims Innocent, Prosecution Story Untrustworthy" – Court Grants Benefit of Doubt

The Supreme Court expressed serious reservations on the alleged motive, stating that while the accused allegedly had a quarrel with PW-1’s son, no plausible reason was offered for the killing of two unrelated individuals – Krishna Kant Verma and Banarasi (the generator operator).

Crucially, the post-mortem revealed close-range gunshot injuries, suggesting the deceased were deliberately targeted, which undermined the theory that they were accidental victims of indiscriminate firing.

“If the accused intended to kill PW-1, who was nearby, it is inexplicable why he escaped unscathed, and instead two innocents were shot at point-blank range. This throws the prosecution version into serious doubt,” the Court noted.

“Trial Court And High Court Erred In Relying Solely On PW-1 Without Independent Corroboration” – Conviction Set Aside

The Bench held that the Trial Court and the High Court erred in overlooking serious flaws in the prosecution’s case, and relying solely on PW-1 despite the absence of corroboration, forensic incongruities, and credible motive.

“The benefit of doubt, which is the bedrock of criminal jurisprudence, must go to the accused when the prosecution version is riddled with such glaring inconsistencies,” the Court held.

Accordingly, the conviction and sentence of Anjani Singh were set aside, and he was acquitted of all charges, with a direction that his bail bonds be discharged. The appeal was allowed in full.

Date of Decision: January 5, 2026