Evidence Of Interested Witness Requires Extra Caution; Cannot Support Conviction If Contradicted By Other Proof: Supreme Court Acquits Murder Accused

"Discrepancies and inconsistencies in the testimony of a related or interested witness will have to be viewed in such context, and more particularly when other evidence on record sufficiently demolishes the evidence of the related or interested witness, its evidence would entirely lose its reliability to stand in support of the prosecution," Supreme Court, in a significant ruling, has set aside the conviction and life imprisonment of a man accused of murder, observing that the prosecution’s case rested on "weak, contradictory, and crumbling evidence."

A bench comprising Justice Prashant Kumar Mishra and Justice N.V. Anjaria held that the testimony of an interested witness requires extra caution and cannot be the sole basis for conviction when it is effectively demolished by other evidence on record. The Court emphasized that when the very occurrence of an incident is shrouded in doubt, the benefit must go to the accused.

The case reached the apex court as an appeal against a Telangana High Court judgment which had confirmed the appellant's conviction under Sections 302 and 323 of the IPC, along with various provisions of the SC/ST (Prevention of Atrocities) Act. The prosecution alleged that on May 12, 2013, the appellant, Talari Naresh, beat the deceased with a stone following a dispute over the elopement of the appellant’s sister. It was claimed that a village Panchayat had previously ordered the deceased to stay away from the village, a condition he allegedly violated, leading to the fatal confrontation.

The primary questions before the Court were whether the testimony of an interested witness, specifically the mother of the deceased, could be considered reliable despite contradictions from other witnesses. The Court was also called upon to determine the evidentiary value of a medical report that contained irreconcilable discrepancies regarding the time and date of the postmortem examination. Furthermore, the bench examined the legal weight of hostile witness testimonies in discrediting the prosecution’s narrative.

Discrepancies In Medical Evidence Diminish Its Value To Nil

The Court first scrutinized the medical evidence presented by the prosecution through Dr. Sridhar (PW7). The bench noted "noticeable discrepancies" between the Inquest Report and the Postmortem Report regarding the conclusion of the autopsy. While the Inquest Report stated the examination concluded on May 13, 2013, the Postmortem Report indicated it concluded on May 14, 2014. The doctor’s explanation—that he erred due to a 24-hour long shift—was rejected by the Court as one that "hardly inspired credibility."

Relying on the precedent in Ghulam Hassan Beigh vs. Mohammad Maqbool Magrey, the Court reiterated that a postmortem report is not substantive evidence by itself and must be corroborated by oral testimony. Since the medical officer was unable to offer a satisfactory explanation for the irreconcilable dates and the Wound Certificate bore no date at all, the Court held that the evidentiary value of the medical set "stands diminished to nil."

Caution In Appreciating Testimony Of Interested Witnesses

The Court then turned its attention to the testimony of Padmamma (PW1), the mother of the deceased. While acknowledging that a relative's testimony cannot be rejected mechanically, the bench invoked the "note of caution" from the five-judge bench decision in Masalti vs. State of Uttar Pradesh. The Court observed that when a witness has a strong interest in the result, their evidence must be weighed with extreme care to avoid arriving at a "perverted or distorted truth."

"A witness who has a strong interest in the result should not be allowed to be weighed on the same scales with those who do not have such interest in the outcome... under the influence of bias, a man may not be in a position to judge correctly, even if they earnestly desire to do so."

Hostile Witness Statements Can Be Used To Discredit Prosecution Case

The prosecution’s narrative regarding the elopement and the subsequent village Panchayat also crumbled during the trial. Multiple witnesses (PW4 and PW5) denied that any such Panchayat was ever held. Furthermore, Narendar (PW3), who was projected as an eyewitness, turned hostile and testified that he never informed the mother about the incident as claimed. The Court noted that while a hostile witness’s testimony can sometimes support a conviction if corroborated, the reverse is also true.

The bench clarified that the statement of a hostile witness can be properly employed to discredit the prosecution case and support an acquittal. In this case, the interaction of the evidence from the mother (PW1) and the hostile witness (PW3) demolished the "very fulcrum of the prosecution case," making the occurrence of the incident itself highly doubtful.

"The testimony of a hostile witness or statement in the deposition of hostile witness could be properly employed to discredit the prosecution case and a conclusion of acquittal could well be supported through it."

Failure To Examine Independent Witnesses At Busy Public Scene

A significant factor in the Court's decision was the location of the alleged crime. The Investigating Officer and Panch witnesses admitted that the incident occurred on a main road near quarries, a place humming with vehicular traffic and public movement. Despite this, the prosecution failed to examine any independent witnesses from the vicinity. The bench found it "only reasonable to believe" that such an incident would have been witnessed by many, yet the prosecution relied solely on a "doubtful story" from interested parties.

Furthermore, the Court pointed out that the crime scene was not protected, as the Investigating Officer only visited the site the following day. This lapse, combined with the lack of independent corroboration and the "crumbling" nature of the existing evidence, led the Court to conclude that the Trial Court and the High Court had committed a "concurrent error" in convicting the appellant.

In its concluding remarks, the Supreme Court held that the prosecution had miserably struggled and failed to prove its case beyond a reasonable doubt. The bench set aside the orders of the High Court and the Special Sessions Judge, acquitting Talari Naresh of all charges. The Court ordered his immediate release, stating that the conviction was unsustainable in the wake of such weak and contradictory evidence.

Date of Decision: May 13, 2026