Truth May Wear Rags, But It Must Be Recognized: Supreme Court Upholds Conviction in Murder Case Despite Minor Inconsistencies in Eyewitness Testimony

“It is the duty of the Court to sift the grain from the chaff unless there is reason to believe that the inconsistencies or falsehood are so glaring as utterly to destroy confidence in the witnesses” – Supreme Court on the Credibility of Related Witnesses in Murder Trials

In a powerful reaffirmation of legal standards governing appellate interference in criminal acquittals, the Supreme Court of India upheld the conviction of five men who had been earlier acquitted by the trial court in a brutal daylight murder case. The case involved a gruesome killing carried out with sickles and ninja chains in Tamil Nadu in 2007. While the Sessions Court had acquitted all the accused citing contradictions and delay, the High Court reversed the verdict against five of them, and the Supreme Court has now affirmed that reversal.

The Court declared that “when a premeditated act is committed in furtherance of a shared design, liability attaches equally to all, irrespective of individual injury inflicted,” emphasizing that the collective intent and execution formed the crux of criminal liability under Section 302 read with Section 34 of the Indian Penal Code.

"Every Contradiction is Not a Confession to Falsehood": Supreme Court Reiterates Approach to Testimony in Indian Context

The primary legal issue before the Court was whether the High Court had erred in overturning the acquittal recorded by the trial court, particularly when the trial judge had noted several inconsistencies in witness accounts and potential procedural gaps in investigation.

Justice Dipankar Datta, writing for the Bench, addressed this head-on by stating, “Witnesses are prone to forget events and things; they are likely to exaggerate or even have motives to change their story… As this Court said in Anil Singh, witnesses add embroidery to the prosecution story, perhaps for fear of being disbelieved.”

The Court further observed, “Should the version be flawless, that might raise eyebrows about the quality of their testimony. After all, it is the duty of the court to sift the grain from the chaff.”

This crucial interpretation reaffirmed the Indian judiciary’s long-standing acknowledgment that eyewitnesses in India, particularly in rural or semi-literate settings, cannot be expected to deliver picture-perfect versions of traumatic events.

"Delay in FIR Forwarding Is Not Always Fatal": Supreme Court Rejects Trial Court’s Perversity on Procedural Delay

One of the principal grounds on which the Sessions Court had acquitted the accused was a perceived delay of nearly 14 hours in forwarding the FIR to the jurisdictional Magistrate, raising suspicion of manipulation.

The Supreme Court rejected this speculation outright. “There is justification provided through the evidence of PW-26 (Head Constable). He stayed overnight to ensure that the FIR reaches the magistrate, which stands proved by reason of the document, being Exhibit P-19, containing the signature of the Magistrate with date and time,” the Court noted.

It held that the trial court had adopted an “illusionary” approach, drawing unfounded inferences from procedural delay without appreciating the surrounding circumstances and evidence.

“Related Witnesses Not Automatically Unreliable”: Supreme Court Restores Credibility to Kin of Victim

A major thrust of the defence’s argument was the relationship of PWs 1 and 2 with the deceased, pointing out that they were his brother-in-law and brother respectively, and had a motive to falsely implicate the accused.

The Supreme Court disagreed, stating, “Merely because PWs 1 and 2 were related to the victim can afford no ground to discredit their evidence.” The Court referred to State of U.P. v. Anil Singh and Ramesh Prasad Misra to hold that related witnesses are not per se unreliable, particularly when their presence at the scene of crime is natural and corroborated by medical and circumstantial evidence.

It observed that “the conduct of PWs 1 and 2 was natural, faced with the threat of being physically harmed by the appellants… The trial court based its conclusions on imaginary and illusionary reasons.”

“Motive, Medical, and Material Evidence Formed a Triad of Conviction”: Supreme Court Upholds High Court’s Forensic Analysis

The Court found that the motive, firmly rooted in property disputes and previous police complaints involving A-4 and A-9, was well-established through documentary evidence (Exts. P-38, P-39, and P-42) and corroborated by the depositions of PWs 1, 2, and 8.

The injuries described in the FIR were found to match almost identically with those recorded in the post-mortem conducted by PW-28. The Supreme Court held, “The overt acts attributed to A-1 to A-4 in the FIR… is corroborated by the corresponding injuries found by PW-28. Significantly, the post-mortem examination was conducted… after the FIR was handed over to the magistrate. Question of manipulation did not, thus, arise.”

The apex court also attached probative value to circumstantial evidence, including the recovery of a broken ninja chain at the scene, sniffer dog trail leading to A-4’s house, and the recovery of nine sickles under Section 27 of the Indian Evidence Act.

“Misapplication of Masalti Will Not Save Accused When Testimonies Are Natural and Corroborated”: SC Clarifies Group Liability Standard

The defence had relied heavily on the ruling in Masalti v. State of U.P., to argue that in the absence of four consistent eyewitnesses, no conviction could be sustained in a group offence. The Supreme Court rejected this rigid interpretation, stating that “Masalti is not a mechanical test, but a rational one… In this case, the presence of two natural eyewitnesses, corroborated by medical and forensic evidence, is sufficient.”

Specifically addressing A-10’s challenge on the ground that his name did not appear in the FIR, the Court said, “A-10 was named by PWs 1 and 2 as one among the several accused on the day following the incident of crime… which finds corroboration from the evidence of PW-28 together with his report on post-mortem (Ext. P-25).”

The Court refused to treat the omission in the FIR as fatal, noting the proximity in time and the precision with which injuries were matched to the alleged assailants.

Trial Court’s Acquittal Was Based on Speculative Reasoning, Not Law or Evidence

In conclusion, the Court held that “the findings returned by the High Court, on a fair and proper appreciation and analysis of the evidence on record, point unerringly towards the guilt of the appellants and that there is no perversity in the decision of the High Court.”

It dismissed all the appeals, confirming life sentences for the five convicted accused.

This ruling not only clarifies how appellate courts should deal with reversals of acquittals, but also strengthens jurisprudence on assessing witness credibility, the role of minor contradictions, and the limits of procedural delay.

Date of Decision: 19 December 2025