When Witnesses Contradict Each Other and the Crime Scene Itself Is in Doubt, Conviction Cannot Be Sustained: Supreme Court Acquits

“Both witnesses contradict each other, suppress the origin of the incident, and deny each other’s presence — such conflicting versions cannot co-exist within a credible narrative,” holds Supreme Court

In a powerful reaffirmation of the core principles of criminal jurisprudence, the Supreme Court of India on 17 October 2025 overturned the conviction of four men in a 35-year-old murder case from Madhya Pradesh, ruling that the prosecution had “suppressed the genesis of the crime and materially shifted the place of occurrence,” rendering its entire case “doubtful and unsafe for conviction.”

The bench of Justice Sanjay Karol and Justice Sandeep Mehta, while deciding Kannaiya v. State of Madhya Pradesh, Criminal Appeal No. 116 of 2012, held that the testimonies of both alleged eyewitnesses were riddled with contradictions, omissions, and improbabilities, and failed to establish the case beyond reasonable doubt. Invoking Article 142 of the Constitution, the Court extended the benefit of acquittal even to the co-convicts who had not approached the Court, calling them “similarly situated accused who deserve parity in the interest of justice.”

The ruling is a landmark in reinforcing the constitutional guarantee of fair trial and the evidentiary threshold in criminal cases.

“Testimonies Built on Inconsistencies Cannot Be the Bedrock of Conviction”: Court Classifies Key Prosecution Witness as “Wholly Unreliable”

At the heart of the case was the death of Ramesh, who succumbed to injuries allegedly inflicted by the appellant Kannaiya and others on the night of 28 September 1990 in village Chak, Madhya Pradesh. The prosecution claimed Ramesh was attacked with swords, axes and sticks when he tried to stop the accused from demolishing a hut. The trial court convicted four persons and acquitted six. The conviction was affirmed by the Madhya Pradesh High Court in 2009, which led to the present appeal.

However, the Supreme Court found the entire prosecution narrative deeply suspect, particularly due to the evidence given by two supposed eyewitnesses—Madho Singh (PW-5) and Puniya (PW-12).

The Court delivered a sharp critique of both witnesses, stating:

“Both these witnesses have given highly contradictory versions regarding the manner in which the incident started and the place where Ramesh was assaulted. Each denies the presence of the other at the crime scene in their depositions.”

On the reliability of Puniya (PW-12), the Court was categorical:

“We have no hesitation in concluding that Puniya (PW-12), falls within the category of a wholly unreliable witness.”

The Court noted that Puniya failed to offer any help to his cousin Ramesh, did not even attempt to intervene or seek help, and his name was omitted from the FIR despite being a close family member and an alleged eyewitness. The Bench declared this a “vital omission,” observing:

“Had he actually seen the incident, this fact was bound to crop up in the family’s discussion and would definitely have reflected in the FIR.”

Similarly, Madho Singh (PW-5) was found to be “partially reliable,” but only in a limited sense. His testimony was sharply questioned for being inconsistent with the FIR and the site inspection plan:

“The witness (PW-5) claimed to be present at the scene, standing two steps away while Ramesh was being assaulted by multiple armed men, yet he escaped without a scratch—this defies logic and raises serious doubts on his presence.”

The Court was equally troubled by his political affiliations, as he admitted enmity with the accused on account of political rivalry, further impugning his credibility.

“The Crime Scene Has Been Shifted, and the Story Built Around It Is Unworthy of Trust”: Court Condemns Suppression of Truth

A key basis for the reversal of the conviction was the Court’s finding that the prosecution had altered the place of occurrence, which went to the root of the case.

The FIR alleged that the assault took place when the accused tried to demolish Jagya’s hut, but the eyewitnesses placed the incident variously in Gopya’s field, Bholiya’s field, and near Narsingh’s house—none of which matched the initial version or the site inspection plan (Exh. P-6).

The Court called out this contradiction in no uncertain terms:

“The prosecution has failed to establish the genesis of the occurrence and the place of incident with any degree of certainty… Such conflicting versions cannot co-exist within a credible narrative.”

Referring to earlier Supreme Court decisions including Pankaj v. State of Rajasthan and Bhagwan Sahai v. State of Rajasthan, the Bench emphasized that when the origin and manner of the incident is shrouded in doubt, conviction must be reversed:

“When the genesis and the manner of the incident is doubtful, the accused cannot be convicted.”

The Court went on to state:

“Suppression of the genesis and shifting of the crime scene demolish the very substratum of the prosecution case.”

“Prosecution's Failure to Prove the FIR, Establish Lighting at the Scene, or Link Weapons to Injuries Proves Fatal”: Conviction Set Aside

The Court noted a series of evidentiary failures in the case that further weakened the prosecution:

• The FIR itself was not proved during trial.

• No source of light was noted at the alleged scene of assault, casting doubt on how eyewitnesses could have clearly identified the attackers or weapons.

• The weapons recovered under Section 27 of the Evidence Act were never conclusively linked to the injuries on Ramesh’s body.

• The FIR was lodged the next morning, with no plausible explanation for the delay.

The Court found it unsafe to rely on the prosecution’s version, particularly when six co-accused were already acquitted on similar evidence:

“Six accused persons who were named by Madho Singh (PW-5) in his deposition as having jointly assaulted Ramesh were acquitted by the trial Court, and their acquittal was never challenged. Thus, the accused-appellant is also entitled to acquittal on parity.”

“Conviction Not Sustainable on Flimsy and Contradictory Evidence”: All Four Accused Acquitted by Supreme Court

Convinced that no credible evidence linked the accused to the crime, and that the entire prosecution version stood compromised, the Supreme Court set aside the conviction of Kannaiya, and exercising its powers under Article 142, extended the benefit of doubt to co-convicts Govardhan, Raja Ram, and Bhima, even though they had not filed separate appeals.

“Since the entire case of the prosecution has fallen, all four convicted accused persons are entitled to the benefit of doubt.”

Accordingly, the judgments of the Trial Court and the High Court were quashed, and all four were ordered to be released forthwith, unless required in any other case.

“We are persuaded to hold that the conviction does not stand to scrutiny”: Supreme Court underscores the need for consistent, credible prosecution evidence

This verdict serves as a cautionary tale for prosecuting agencies and lower courts, reminding them that a criminal conviction must rest on unimpeachable, coherent, and credible evidence. Where inconsistencies abound, and key witnesses contradict each other on fundamental facts, the benefit of doubt must go to the accused—not as a matter of charity, but as a matter of constitutional guarantee.

Date of Decision: 17 October 2025