Testimony Of Related Witnesses Cannot Be Discarded Merely For Relationship: Supreme Court Upholds Murder Conviction

“Minor Discrepancies Or Allegedly Unnatural Behaviour Do Not Make Credible Evidence Unreliable”, In a significant ruling on the evidentiary value of related witnesses in criminal trials, the Supreme Court held that testimony of witnesses who are related to the deceased cannot be rejected solely because of their relationship, if their evidence is otherwise consistent and trustworthy.

The Bench of Justice Pankaj Mithal and Justice S.V.N. Bhatti upheld the conviction and life imprisonment of the accused for murder under Sections 148 and 302 read with Section 149 of the Indian Penal Code.

The Court clarified that relationship of witnesses with the victim is not a ground to discard their testimony, particularly when the evidence is corroborated by medical and other circumstantial material.

The Court observed:

“Evidence of related witnesses cannot be discarded merely on the ground of relationship if their testimony is consistent and credible.”

Background of the Case

The case arose from the murder of Balkishan, who was the Chairman of the Watershed Committee.

On 3 June 2000, Balkishan was waiting at Tihuli bus stand when six accused persons allegedly arrived together in a bus carrying firearms. The prosecution alleged that the main accused Vikram fired the first shot, after which the deceased ran towards the village in an attempt to save his life.

The accused chased him while firing and eventually shot him inside the house of Rattan Lal, where he died due to multiple gunshot injuries.

The FIR was lodged by Budha Ram, the brother of the deceased, shortly after the incident.

Following trial, the accused were convicted by the Trial Court and sentenced to life imprisonment, and the conviction was subsequently affirmed by the Madhya Pradesh High Court.

Defence Challenge to Witness Testimony

Before the Supreme Court, the appellants argued that the prosecution case rested largely on the testimony of family members of the deceased, including his brother, son and nephews.

It was contended that these witnesses were interested witnesses and their statements contained contradictions and improvements, making their evidence unreliable.

The defence further argued that their conduct was unnatural because none of them attempted to rescue the deceased or take him to the hospital, despite allegedly witnessing the attack.

Supreme Court On Evidence Of Related Witnesses

Rejecting the arguments of the appellants, the Supreme Court held that relationship of witnesses with the victim does not by itself render their testimony unreliable.

The Court emphasized that criminal courts must evaluate such evidence on the basis of its intrinsic credibility and consistency, rather than rejecting it solely on the ground of relationship.

The Bench observed that the testimonies of the deceased’s relatives were substantially consistent with each other and were corroborated by other evidence on record.

The Court further clarified that even if some aspects of witness behaviour appear unusual, such as failure to intervene during the attack, that alone cannot discredit otherwise reliable testimony.

The Bench noted:

“Their conduct may appear unnatural in not attempting to save the deceased, but nothing much hinges upon that in the light of the other evidence on record.”

Independent Witness And Corroborative Evidence

The defence relied on the testimony of Rattan Lal, an independent witness, who stated that he did not see the accused firing inside his house but only heard gunshots.

The Supreme Court held that this fact did not weaken the prosecution case because other witnesses had clearly stated that the accused chased the deceased and fired multiple shots.

Moreover, the medical evidence showing multiple firearm injuries and the recovery of cartridges from the courtyard supported the prosecution version of events.

Conviction Upheld

After evaluating the evidence, the Supreme Court concluded that the findings of the Trial Court and the High Court were well supported by the material on record.

The Court held that there was no legal infirmity warranting interference with the conviction, and therefore dismissed the appeals.

Since the appellants were on bail during the pendency of the appeals, the Court directed them to surrender immediately to undergo the remaining sentence.

The judgment reiterates a well-settled principle of criminal law that testimony of related witnesses cannot be rejected merely because of their relationship with the victim.

Courts must instead examine whether the evidence is credible, consistent and supported by other material evidence. Where such testimony inspires confidence, it can safely form the basis of conviction even in serious offences like murder.

Date of Decision: 11 March 2026