In a significant ruling, a bench of the Supreme Court comprising Justice Vikram Nath and Justice Prasanna B. Varale dismissed the appeals in Criminal Appeal No. 1675 of 2015 filed by four individuals convicted of murder. The judgment reaffirmed the principle that a witness’s familial relationship with the victim does not inherently discredit their testimony, provided it is credible and consistent. The court upheld the High Court’s verdict, which had reversed the trial court’s acquittal, convicting the accused under Section 302 read with Section 34 of the Indian Penal Code (IPC).
Case Background
The case stemmed from the brutal murder of Lalsaheb in Brahmanwadi, Maharashtra, on September 26, 1987. The prosecution alleged that long-standing property disputes among family members culminated in the attack. Accused Nos. 1 to 4—Baban, Prakash, Suresh, and another family member—assaulted Lalsaheb with sticks, causing fatal injuries. The victim’s wife, Kamal (PW-3), daughter Sushila (PW-4), and son Sanjay (PW-7) witnessed the crime and provided key testimony.
The trial court initially acquitted all the accused, citing inconsistencies in witness accounts and perceived gaps in the prosecution’s case. However, the High Court, upon reappraisal, convicted the four primary accused, leading to the present appeal.
Important Legal Issues
1. Credibility of Related Witnesses: The central issue was whether the testimony of family members (PW-3, PW-4, and PW-7) should be discounted due to their close relationship with the deceased.
2. Corroboration Between Eyewitness and Medical Evidence: The appellants argued that discrepancies between medical evidence and eyewitness accounts rendered the latter unreliable.
3. Assessment of Minor Inconsistencies: The case also examined whether minor contradictions in testimony could undermine the prosecution’s case.
Key Observations of the Court
The Supreme Court provided the following critical observations:
– On Credibility of Related Witnesses:
Referring to precedents such as Dalip Singh v. State of Punjab and Pruthviraj Jayantibhai Vanol v. Dinesh Dayabhai Vala, the bench stated,
“Merely because witnesses are related to the victim does not automatically render them biased. A close relative is usually the last person to falsely implicate another, particularly in a case involving the murder of a family member.”
– On Minor Inconsistencies:
The court reiterated that minor discrepancies in testimony, especially in cases involving sudden and violent crimes, do not negate the core narrative.
“Eyewitnesses subjected to trauma may not recall every detail with precision, but their testimony must be assessed for overall coherence and credibility.”
– On Medical Evidence:
The bench clarified that while medical evidence plays a corroborative role, it need not perfectly align with eyewitness accounts. It stated,
“The absence of multiple head injuries in the post-mortem report does not negate the possibility of repeated blows; it reflects the limitations of forensic documentation.”
Decision of the Court
After a meticulous review of the evidence, the Supreme Court upheld the High Court’s conviction of the accused under Section 302 read with Section 34 of the IPC. The court observed that the trial court erred in acquitting the accused by placing undue emphasis on minor inconsistencies while disregarding substantial evidence, including credible eyewitness accounts and corroborative medical reports.
The bench dismissed the appeal, concluding:
“The evidence presented, when viewed in its entirety, establishes the guilt of the accused beyond reasonable doubt. The testimony of related witnesses, supported by medical evidence, cannot be discarded on trivial grounds.”
