Supreme Court Declines To Restore Murder Conviction Due To Doubts Over Medical Intimation Timing And Omissions In Prosecution Case

"There is a doubt created with regard to the time when such intimation was actually given by PW8 and received by PW10. The overwriting on Exhibit P6 at the instance of PW10 further enhances such doubt." Supreme Court, in a judgment dated August 10, 2026, held that material inconsistencies in police records regarding the timing of medical intimations and a highly detailed dying declaration in cases of multiple grievous injuries can create fatal doubts in the prosecution's case.

A bench of Ujjal Bhuyan and Atul S. Chandurkar, JJ. observed that the evidence on record was insufficient to restore a conviction under Section 302 IPC, upholding instead the High Court's modification of the sentence to Section 304 Part II of the Indian Penal Code, 1860.

The State of Andhra Pradesh challenged a 2014 judgment of the High Court of Andhra Pradesh which had altered the respondents' conviction under Section 302 read with Section 34 IPC to Section 304 Part II IPC, reducing their life imprisonment to six years of rigorous imprisonment. The prosecution alleged that on the intervening night of March 8 and 9, 2006, the respondents attacked the victim with sickles and iron pipes due to long-standing family feuds. The injured victim was allegedly taken to a hospital where his statement was recorded before he succumbed to his injuries.

The primary question before the court was whether the High Court erred in altering the conviction from murder under Section 302 IPC to culpable homicide not amounting to murder under Section 304 Part II IPC. The court was also called upon to determine the evidentiary value of a detailed dying declaration recorded when the victim had sustained twenty-two serious injuries.

Discrepancies In Prosecution Evidence Court Flags Material Contradictions Regarding Scene And Transport

The bench closely examined the testimonies of material witnesses, noting stark contradictions regarding the crime scene and how the injured victim was transported. While the alleged eyewitness claimed the victim was assaulted in his fields and carried to a graveyard before being taken home, other prosecution witnesses claimed the victim was shifted directly in a jeep. The court pointed out that these glaring discrepancies created serious doubts regarding the actual site of occurrence and the presence of the accused immediately thereafter.

Doubt Over Medical Intimation Timing Court Highlights Overwritings And Corrections In Police Records

The Supreme Court scrutinized the documentary evidence concerning the medical intimation sent by the doctor to the police. While the civil assistant surgeon stated he sent intimation at 05:30 a.m., the police officer recorded receiving it after correcting an earlier entry. The court observed that overwriting and unexplained corrections regarding time heavily dented the veracity of the prosecution's timeline.

Unnatural Detail In Dying Declaration Detailed 'Blow By Blow' Account Raises Suspicion

Addressing the evidentiary weight of the victim's statement recorded as Exhibit P10, the bench expressed deep skepticism over its extensive detail. The statement ran into a page and a half, providing a vivid 'blow by blow' account of the incident and past enmity. The court held that considering the victim had suffered twenty-two injuries, many of them grievous, such a detailed narration by a seriously injured person under medical treatment raised serious doubts, especially when the effect of tranquilizers could not be ruled out.

Disapproval Of High Court's Surmises Supreme Court Rejects Conjectures While Sustaining Modification

While the Supreme Court dismissed the State's appeal against the reduction of sentence, it explicitly disapproved of certain observations made by the High Court. The High Court had opined that armed assailants intending to kill would normally confirm the victim's death before leaving. The apex court held that these observations were based purely on surmises and conjectures. However, the bench ruled that despite this flawed reasoning, the overall evidence on record was indeed insufficient to restore a conviction under Section 302 IPC.

Final Verdict And Order Matter Brought To A Quietus As Respondents Served Sentence

Noting that the private respondents had already suffered the sentence of six years of rigorous imprisonment imposed by the High Court and had not challenged their modified conviction, the Supreme Court concluded that the matter deserved a quietus. The criminal appeal filed by the State of Andhra Pradesh was accordingly dismissed.

Date of Decision: 10 August 2026