Conviction can’t rest on unreliable sole testimony: High Court Acquits Murder Convict Citing Unreliable Eyewitness Testimony

The High Court of Judicature at Patna has overturned the conviction of Ranjit Yadav @ Karu Yadav, acquitting him of the charges of murdering Girija Devi. The judgment, delivered by Justices Ashutosh Kumar and Jitendra Kumar, emphasized the unreliability of the sole eyewitness testimony and the lack of corroborative evidence. The decision comes after the trial court had convicted Yadav under Sections 302 of the Indian Penal Code (IPC), Section 27(1) of the Arms Act, and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.

The case arose from the alleged murder of Girija Devi on March 18, 2015. According to the prosecution, the appellant, Ranjit Yadav, shot Girija Devi while she was returning home with her mother-in-law, Kauleshri Devi (the informant), and others. Kauleshri Devi claimed to have witnessed the incident, leading to Yadav’s conviction by the trial court. However, several key witnesses, including Punam Kumari @ Sonam Kumari, Sangita Devi, and Saroti Kumari, turned hostile, weakening the prosecution’s case.

The High Court critically evaluated the reliability of the sole eyewitness, Kauleshri Devi. The court noted significant contradictions in her statements. Despite claiming to have seen the appellant shoot Girija Devi, she later admitted in cross-examination that she was at home, approximately a mile away from the scene, when the incident occurred. This discrepancy cast serious doubt on her credibility.

“The informant’s presence at the place of occurrence is highly questionable, given her admission of being at home during the incident,” observed the court.

The court also addressed the issue of hostile witnesses. Out of the key witnesses, including Punam Kumari @ Sonam Kumari (PW-2), Sangita Devi (PW-7), and Saroti Kumari (PW-8), none supported the prosecution’s case. This lack of corroboration further weakened the case against the appellant.

“The prosecution’s inability to provide consistent witness testimony significantly undermines the reliability of the charges,” the bench stated.

No motive for the murder was established, and the weapon allegedly used in the crime was not recovered. The investigating officer admitted to not finding any incriminating evidence at the scene, such as an empty cartridge or blood stains. This absence of substantive evidence was crucial in the court’s decision to acquit.

“The failure to recover the weapon and establish a clear motive adds to the reasonable doubt regarding the appellant’s involvement,” the judgment noted.

The court reiterated the principle that a conviction cannot be sustained solely on the basis of an unreliable testimony. It emphasized the necessity for credible and consistent witness accounts, especially in the absence of direct evidence linking the accused to the crime.

“In criminal jurisprudence, the benefit of doubt must be given to the accused if the evidence is not conclusive,” stated Justice Ashutosh Kumar. “The sole testimony of PW-1, marred by inconsistencies, does not meet the standard required for a conviction.”

Justice Ashutosh Kumar remarked, “The informant’s account is replete with contradictions, casting serious doubt on her presence at the crime scene. In the absence of corroborative evidence and the presence of hostile witnesses, the conviction cannot stand.”

The High Court’s decision to acquit Ranjit Yadav underscores the judiciary’s commitment to upholding the principles of justice and the necessity for credible evidence in criminal convictions. This judgment highlights the importance of reliable witness testimony and the requirement for substantial evidence in sustaining convictions. The acquittal of Yadav sends a clear message about the high evidentiary standards required in criminal cases, particularly those involving severe charges such as murder.

Date of Decision: July 08, 2024