Conviction Cannot Rest on Unreliable Eyewitnesses and Mere Recovery of Weapon: Supreme Court Acquits Murder Accused

When the Prosecution Fails to Prove Guilt Beyond Reasonable Doubt, Acquittal is the Only Option – Supreme Court set aside the conviction of the appellant under Section 302 IPC, ruling that unreliable eyewitness testimony coupled with the mere recovery of a weapon is insufficient to sustain a conviction. The Court acquitted the appellant, holding that the prosecution failed to establish guilt beyond reasonable doubt, as mandated by criminal jurisprudence.

"In a case of murder, where the prosecution relies solely on eyewitnesses, their testimony must be free from material contradictions and omissions. The law does not permit conviction on the basis of shaky, unreliable, or self-contradictory evidence. When the prosecution fails to establish the guilt of the accused beyond reasonable doubt, the benefit of doubt must go to the accused," the Supreme Court observed.

The case arose from an incident on December 31, 2010, where the appellant was accused of stabbing and killing Ramakrishnan due to previous enmity. The Trial Court convicted him under Section 302 IPC and sentenced him to life imprisonment, which was later upheld by the Kerala High Court. The Supreme Court, however, found serious flaws in the prosecution's case, including unreliable eyewitness accounts and an unexplained failure to produce crucial witnesses.

"Contradictory and Untrustworthy Eyewitness Testimony Cannot Form the Basis of Conviction"

The prosecution primarily relied on two alleged eyewitnesses, PW-4 and PW-5, to prove the case against the appellant. However, the Supreme Court noted multiple inconsistencies in their statements, omissions of crucial facts, and unnatural conduct, which rendered their testimony unreliable.

"The testimony of an eyewitness must be consistent, coherent, and inspire confidence. If key details such as the number of stab wounds, the sequence of events, or even their own presence at the scene are contradicted or omitted in their statements, their reliability is seriously compromised," the Court held.

The Court found that: PW-4 claimed he witnessed the attack from a distance of 15 feet, yet this fact was missing from his statement to the police. Both eyewitnesses initially stated that the deceased was stabbed on the back, but this was later omitted from their recorded statements. They admitted that several other people were present at the scene, yet the prosecution failed to produce these key witnesses. Neither of the eyewitnesses made any immediate attempt to take the deceased to the hospital or inform the police. One of the witnesses (PW-4) admitted that he himself was a co-accused in the murder of the appellant’s brother, raising serious doubts about his impartiality. Based on these findings, the Supreme Court discredited the testimony of PW-4 and PW-5, holding that their statements were riddled with material contradictions and omissions.

"Courts must be cautious in relying upon eyewitness testimony, especially when the witnesses have prior enmity with the accused. The burden of proving guilt is always on the prosecution, and it cannot rest on doubtful testimony," the Court emphasized.

"Recovery of the Weapon Alone Cannot Establish Guilt Without Corroborative Evidence"

Another crucial point addressed by the Supreme Court was the recovery of the alleged murder weapon at the appellant's instance, which was heavily relied upon by the prosecution. The Court reiterated the settled principle that mere recovery under Section 27 of the Indian Evidence Act cannot form the sole basis of conviction.

Referring to its earlier ruling in Manoj Kumar Soni v. State of M.P., 2023 SCC OnLine SC 984, the Court observed: "A doubt looms: can disclosure statements per se, unaccompanied by any supporting evidence, be deemed adequate to secure a conviction? We find it implausible. Although disclosure statements hold significance as a contributing factor in unraveling a case, they are not so strong a piece of evidence sufficient on their own to bring home the charges beyond reasonable doubt."

The Court held that since the eyewitness accounts were unreliable and there was no independent corroboration of the appellant’s involvement, the recovery of the weapon alone could not establish his guilt.

"A recovery must be linked with credible evidence proving the crime. If the foundational evidence is weak, the mere fact that a weapon was recovered does not establish guilt," the Court ruled.

"Standard of Proof in Criminal Cases Must be Strictly Adhered to"

The Supreme Court reaffirmed the fundamental principle of criminal law that the prosecution must prove its case beyond a reasonable doubt. It held that in this case, the evidence presented was insufficient to meet that standard.

"The law is clear: suspicion, however strong, cannot take the place of legal proof. The prosecution must establish the guilt of the accused beyond a reasonable doubt, and if it fails, the accused must be acquitted. It is not the accused who must prove his innocence, but the prosecution that must prove his guilt," the Court emphasized.

Given the absence of credible eyewitness testimony and the lack of substantive evidence, the Court quashed the conviction and ordered the appellant’s immediate release, unless required in any other case.

"A person cannot be kept behind bars for twelve years on the basis of unproven allegations. The rule of law demands that no individual be deprived of his liberty unless the charges against him are proven in a fair and just trial," the Supreme Court declared.

A Strong Reminder of the Need for Rigorous Judicial Scrutiny in Criminal Trials

This judgment serves as a crucial reminder of the necessity for courts to rigorously scrutinize evidence in criminal cases and not convict an accused merely based on weak, contradictory, or unreliable testimony.

By reversing the conviction and acquitting the appellant, the Supreme Court has once again reiterated the importance of upholding the presumption of innocence and ensuring that every conviction is based on unimpeachable evidence.

With this ruling, the Supreme Court has set an important precedent, reaffirming that criminal trials must be conducted with the highest standards of fairness and that courts must remain vigilant in ensuring that no individual is convicted unless the prosecution has established guilt beyond a reasonable doubt.

Date of decision: 29/01/2025