Citing Corroboration is Crucial in Witness Testimony, Supreme Court Overturn The Conviction In Murder Case.

The Supreme Court overturned the conviction of convicts, emphasizing the critical importance of corroborating witness testimony, particularly when the witness is deemed to be interested or when their reliability is questionable. The prosecution relied heavily on the evidence of Sindhubai (PW-1), the wife of one of the deceased and sister-in-law of the other deceased, whose account of how the two victims ended up dead was the core evidence upon which the initial conviction of the trial court was premised.

The prosecution case believed that Rajkumar and Mehatar, along with others, had committed offenses under Sections 147, 148, 452, and 302 read with Section 149 of the Indian Penal Code (IPC). The occurrence arose out of past disputes between the complainant, Sindhubai, and the accused, Rajkumar, regarding damage to her property by the accused's cattle.

The prosecution further contended that the accused, Baburao, had a dispute with one of the deceased, Shyamrao, over a piece of land. On the day of the incident, Sindhubai reported that Rajkumar verbally abused her husband and brother-in-law, leading her to file a complaint at the police station. Later, a group of individuals, including the accused, allegedly assaulted her brother-in-law, Shyamrao, resulting in his death.

The Trial Court convicted all ten accused, however, when appealed before the High Court, six accused were acquitted and while the High Court convicted Rajkumar, Baburao, and Mehatar.

Supreme Court: The Supreme Court observed that the High Court itself had deemed parts of Sindhubai’s testimony as unreliable while still upholding the conviction, and this inconsistency raised serious doubts about the veracity of the evidence presented.

Citing lack of corroboration, the Apex Court observed another most significant aspect was that Sindhubai's account had no corroborative evidence, and they key witnesses, such as Sitabai, Tekaram Rahagadale, and the Sarpanch of the village, were not cross-examined during court proceedings, and thus Sindhubai's account remained uncorroborated.

The Apex Court futher noted that Sindhubai was an "interested witness" due to her relationship with the deceased and observed the need for a more cautious and prudent scrutiny of her evidence.

Relying on its earlier Judgment in case of "Vedivelu Thevar Precedent vs State of Madras" (Click to Download) the Apex Court reiterated the established legal principle that corroboration is required where the credibility of a witness is questionable. The court reiterated that evidence must be weighed, not counted, and that the quality of one witness's evidence must be of sterling quality in order to sustain a conviction.

The Supreme Court, thus, released Mehatar and Rajkumar on acquittal after establishing that they were accorded the benefit of the doubt due to lack of credible and corroborated proof. The court struck down judgments and orders of conviction entered by the High Court and trial court and ordered release of Rajkumar unless otherwise detained in some other case, releasing Mehatar on bail bonds.

Coram: Justice B. R. Gavai and Justice K. Vinod Chandran
Case: MEHATAR VS THE STATE OF MAHARASHTRA 2025 INSC 2016 Caseguru
Judgment Date: 11-02-2025