Sole Eyewitness Testimony Of Relative Sufficient For Conviction If Credible: Supreme Court

"As a general rule, a court can and may act on the testimony of a single witness though uncorroborated. One credible witness outweighs the testimony of a number of other witnesses of indifferent character." Supreme Court, in a significant ruling, held that the uncorroborated testimony of a sole eyewitness who is a close relative of the deceased is entirely legally sustainable to secure a conviction, provided the testimony inspires complete confidence and remains unshaken during cross-examination.

A bench comprising Justice Prashant Kumar Mishra and Justice N.V. Anjaria observed that the legal system is concerned with the quality rather than the quantity of evidence, reiterating that Section 134 of the Indian Evidence Act, 1872, mandates that no particular number of witnesses is required for the proof of any fact.

The case originated from an incident on February 17, 1998, in District Sundargarh, Odisha, where a young girl died, and local villagers blamed her death on witchcraft practiced by the deceased, Puni Naik. The appellant Balku Oram and a co-accused dragged Puni Naik from her home and severely assaulted her with a lathi, resulting in her death early the next morning. The victim's 15-year-old daughter, Sukra Naik, witnessed the entire brutality. The Trial Court convicted the appellant under Section 302 read with Section 34 of the IPC, sentencing him to life imprisonment, which was subsequently affirmed by the Orissa High Court.

The primary questions before the court were whether the sole testimony of a related eyewitness requires mandatory independent corroboration, and whether the acts constituted murder under Section 302 IPC or culpable homicide not amounting to murder under Section 304 IPC. The court was also called upon to evaluate the legal effect of a minor delay in lodging the FIR.

Court Rejects Contention Against Related Witnesses

The bench firmly rejected the appellant's contention that the sole eyewitness, being the daughter of the deceased, qualified as an interested witness whose testimony must be discarded without corroboration. The court observed that a close relative who is a natural witness cannot be regarded as an interested witness simply by virtue of their familial bond. "The term 'interested' postulates that the person concerned must have some direct interest in seeing that the accused person is somehow or the other convicted either because he had some animus with the accused or for some other reason." Relying on landmark precedents including Vadivelu Thevar v. State of Madras and Shio Shankar Dubey v. State of Bihar, the bench emphasized that ordinarily, a close relative would be the last person to screen the real culprit and falsely implicate an innocent party.

Quality Over Quantity In Criminal Jurisprudence

Evaluating the deposition of P.W.3, the bench noted that her presence at the scene was natural and unquestionable, and her account remained entirely consistent across chief examination and cross-examination. Citing Prithipal Singh v. State of Punjab, the court underscored that the foundational rule of criminal law dictates that evidence has to be weighed and not counted. "The test is whether the evidence has a ring of truth, is cogent, credible and trustworthy or otherwise." The bench cautioned that insisting on a plurality of witnesses as an absolute rule would indirectly encourage the subornation of witnesses and leave crimes committed in isolation unpunished.

Intention Determined By Nature Of Injuries

Addressing the alternative plea that the offence fell under Section 304 Part I or Part II of the IPC due to grave and sudden provocation, the bench examined the post-mortem report detailing multiple severe injuries across vital organs including the head, neck, and chest. Relying on the principles laid down in Pulicherla Nagaraju alias Nagaraja Reddy v. State of A.P., the court held that intention to cause death must be gathered from the nature of the weapon, the targeted body parts, and the brutality of blows. The bench observed that multiple grievous injuries inflicted on vital parts manifest a clear intention to cause death, precluding any benefit under the exceptions to Section 300 IPC.

Delay In FIR Explained By Natural Shock

On the issue of the one-day delay in registering the FIR, the bench reiterated the doctrine established in Om Pal v. State of U.P. and Ramdas v. State of Maharashtra that delay is not fatal if adequately explained by the surrounding facts and circumstances. Given that the sole eyewitness was a 15-year-old girl who had just witnessed the brutal murder of her mother, it was entirely natural for her to remain in a state of shock and despair until her maternal uncle arrived to assist her in approaching the police station the following morning.

Court Condemns The Malaly Of Witch-Hunting

In a powerful closing obiter dictum, the bench expressed deep anguish over the persistence of witch-hunting in modern society, characterizing it as an anathema to human dignity and constitutional morality. The court observed that superstition, prejudice, and irrational fear continue to victimize vulnerable women, overriding the rule of law. "A Constitutional democracy such as ours cannot survive; wherein such derogatory practices continue to elude the principles of rule of law and Constitutional morality." The bench emphasized that 'reason' must stand as a bulwark against collective irrationality, concluding that justice must always prevail over superstition.

Concluding that the direct ocular testimony was compelling and fully corroborated by medical evidence, the Supreme Court dismissed the criminal appeal, affirming the concurrent convictions and life sentences imposed by the courts below.

Date of Decision: 13 August 2026