Discrepancy Between Ocular Testimony And Medical Evidence Creates Reasonable Doubt: Supreme Court

"The criminal court cannot pick one apparently corroborated portion while ignoring other material inconsistencies, especially in an appeal against acquittal." Supreme Court of India, in a significant ruling dated July 21, 2026, dismissed an appeal against a concurrent acquittal, holding that where the prosecution’s case suffers from material contradictions between ocular testimony and medical evidence, a conviction cannot be sustained.

A bench of Justices Sanjay Karol and Nongmeikapam Kotiswar Singh observed that a criminal trial is not a "fairy tale" and the prosecution must prove its case beyond reasonable doubt, rather than relying on isolated pieces of evidence.

Failure to Prove Case Beyond Reasonable Doubt

The case originated from a 1998 incident in Nalanda, Bihar, where the deceased, Vinod Prasad, was allegedly shot by four accused persons. While the Trial Court acquitted the respondent, Nakul Prasad, the High Court affirmed this decision, noting a "clear mismatch" between the four gunshot injuries alleged in the FIR and the three entry wounds recorded in the post-mortem report. The Supreme Court underscored that this medical discrepancy, coupled with the hostility of independent witnesses and the reliance on related witnesses, justified the acquittal.

Court Explains the Sanctity of Acquittal

The Bench emphasized that the presumption of innocence is reinforced by an order of acquittal, particularly when it is concurrent. The Court stated that it would not interfere with such findings under Article 136 of the Constitution of India unless the judgment is shown to be perverse, illegal, or results in a manifest miscarriage of justice. It clarified that appellate courts should not overturn an acquittal simply because another view of the evidence is possible.

Medical Evidence as a Tool for Scrutiny

The appellant had argued that the specific injury on the deceased's chin matched the role attributed to the respondent. However, the Court rejected the attempt to isolate this single piece of evidence from the larger context. The judges noted that the prosecution’s version—which attributed specific, separate shots to different assailants—failed to align with the medical findings of only three firearm tracks, thereby creating significant doubt regarding the credibility of the entire narrative.

"Crime is an event in real life and is the product of interplay of different human emotions. In arriving at the conclusion about the guilt of the accused charged with the commission of a crime, the Court has to judge the evidence by the yardstick of probabilities intrinsic worth and the animus of witnesses."

Materiality of Independent Witness Testimony

The Court further addressed the prosecution's failure to examine key independent witnesses named in the chargesheet. While noting that the non-examination of witnesses is not always fatal, the Bench clarified that this principle cannot be applied mechanically. In this instance, because the independent witnesses were material to the case and their absence remained unexplained, the Court held that the prosecution could not expect the judiciary to ignore such a significant void in the evidence.

Cumulative Effect of Infirmities

The judgment also touched upon the relevance of investigative lapses and procedural delays, including a significant gap in the registration of the FIR. The Court observed that while such factors might seem minor in isolation, their cumulative effect was sufficient to cast a shadow on the prosecution’s case. Consequently, the Court found no merit in the appellant's attempt to use extraneous criminal antecedents of the respondent to fill these evidentiary gaps, insisting that the trial must be decided strictly on the evidence related to the 1998 occurrence.

Finality of the Concurrent Acquittal

In its conclusion, the Court reiterated that the doctrine of benefit of doubt is a substantive safeguard, not a mere technicality. Finding no perversity in the findings of the lower courts, the Supreme Court upheld the acquittal, directing that the respondent be discharged of his bail bonds, subject to compliance with the provisions of Section 437-A of the CrPC.

Date of Decision: 21 July 2026