Credible Direct Ocular Evidence Prevails Over Medical Inferences On Digestive Process; Names Of Eyewitnesses Not Mandatory In S.174 CrPC Inquest Report: Supreme Court

 "The attempt by the learned senior counsel for the appellants to create a doubt on the prosecution case by falling back on the inconclusive digestive process is an argument which in itself, on facts, is very difficult to digest." The Supreme Court observed on November 3, 2026, that when acceptable and trustworthy eyewitness testimony proves the time and manner of an assault, speculative medical inferences drawn from gastric contents and digestive timelines cannot override direct ocular proof.

A Bench comprising Justice K.V. Viswanathan and Justice Arun Palli affirmed the High Court's reversal of an acquittal, reiterating that inquest reports under Section 174 CrPC are strictly confined to determining the apparent cause of unnatural death and need not disclose the names of eyewitnesses or overt acts.

The case originated from a midnight assault during the intervening night of September 8 and 9, 2001, where two brothers, Mallappa and Gulappa, were brutally hacked to death with axes following a previous enmity over compensation for an injured goat. The wives of the deceased, sleeping right beside them at their residence and cattle shed, witnessed the gruesome attacks. While the Trial Court acquitted all seven accused by raising doubts regarding power supply, digestive processes, and omissions in the inquest report, the High Court overturned the acquittal, convicting the appellants under Sections 143, 148, 302, 323, and 341 read with Section 149 of the Indian Penal Code and sentencing them to life imprisonment.

Whether the medical opinion estimating the time of death based on gastric contents can outweigh clear and direct ocular testimony of natural eyewitnesses.

Whether the omission of the names of eyewitnesses or details of overt acts in an inquest report prepared under Section 174 of the Code of Criminal Procedure is fatal to the prosecution.

Whether the High Court was justified in reversing the judgment of acquittal recorded by the Trial Court.

Trial Court glorification of non-essentials warranted reversal of acquittal

The Supreme Court reiterated the settled principles governing appeals against acquittals, noting that an appellate court possesses full power to review, re-appreciate, and reconsider the evidence upon which the order of acquittal was founded. The Court noted that an acquittal can be set aside when the reasoning of the lower court is wholly unreasonable, perverse, or direct contradiction to the evidence on record.

Appellate intervention is imperative where Trial Court judgment is totally unsustainable

"To say the least, the Trial Court has discarded crucial evidence that was available to clearly implicate the appellants and has glorified the non-essential aspects which in no manner dilute the direct eyewitness versions of the two spouses of the deceased," the Bench observed, holding that no two views were possible in the matter.

Ocular testimony overrides inconclusive medical speculation regarding stomach contents

Addressing the Trial Court's reliance on the doctor's statement that there was a four-hour gap between the two deaths based on stomach contents, the Apex Court held that digestive duration is inherently variable. Relying on its earlier rulings in Nihal Singh v. State of Punjab and Shivaji Sahabrao Bobade v. State of Maharashtra, the Court noted that digestion depends on the nature of food, individual digestive capacity, health, and shock.

Verdicts cannot be staked on nebulous medical observations over digestive timelines

The Bench underscored that when trustworthy eyewitness accounts establish that the murders occurred in quick succession, no judicial reliance can be placed exclusively on stomachic contents. Describing the defense's strategy, the Bench remarked that attempting to dismantle direct ocular evidence by falling back on the inconclusive digestive process was "an argument which in itself, on facts, is very difficult to digest."

Section 174 CrPC inquest proceedings have a limited and specific statutory purpose

The Court firmly rejected the argument that the testimonies of the eyewitnesses had to be discredited because their names did not appear in Column 7 of the Inquest Panchnama. Reaffirming the authoritative position laid down in Radha Mohan Singh v. State of U.P., the Bench clarified that an inquest report is not intended to be an encyclopaedia of the crime.

Inquest reports need not record details of assailants, overt acts, or eyewitnesses

"The question regarding the details as to how the deceased was assaulted or who assaulted him or under what circumstances he was assaulted or who are the witnesses of the assault is foreign to the ambit and scope of proceedings under Section 174," the Court highlighted. It reiterated that an inquest inquiry under Section 174 CrPC is exclusively confined to ascertaining whether the death was accidental, suicidal, or homicidal, and describing the marks of injury on the dead body.

Spouses are natural witnesses whose testimonies cannot be discarded as interested

The Bench rejected the contention that the wives of the deceased were interested witnesses merely on account of their relationship. The Court reiterated that a related witness is not inherently partisan or interested, noting that the two widows were the most natural witnesses present at the scene during midnight, with one of them also sustaining injuries during the attack.

The Supreme Court dismissed the appeal, upheld the High Court's judgment convicting the appellants under Sections 143, 148, 302, 323, and 341 read with Section 149 IPC, and directed the appellants to surrender forthwith to serve their life sentences.

Date of Decision: November 3, 2026