Supreme Court Overturns Murder Conviction Citing Prosecution Witnesses Untrustworthiness

The current appeal was preferred against the judgment of the High Court of Madhya Pradesh which had confirmed the conviction and life imprisonment under Section 302 of the Indian Penal Code, against the appellant, Aslam alias Imran. The Trial Court had convicted the appellant for murdering Zahid Khan alias Guddu on the basis of an incident where the deceased was stabbed with a butcher knife after the altercation. The prosecution's case rested primarily on the testimonies of several eyewitnesses, including the deceased's brother.

The Supreme Court examined whether the concurrent convictions by the trial court and the High Court were justified on the basis of the evidence led by the prosecution. The Supreme Court critically analyzed the testimonies of the most important prosecution witnesses, i.e., Shahid Khan (PW-1), Rassu (PW-2), Asif Khan (PW-3), and Saiyad Wahid Ali (PW-4), and observed a number of serious inconsistencies and improbabilities in their testimonies.

The Apex Court also noted the lack of bloodstains on the garments of witnesses who purported to have borne the profusely bleeding body of the deceased, and also pointed towards their not reporting to the nearby police station or to a police constable immediately, and inconsistencies in their testimonies concerning their presence and activities at the crime scene.

Furthermore, the Apex Court emphasized the undue delay in recording statements of some witnesses and also that the deceased was a history-sheeter having previous enmity with the appellant and the scope for possible false implication could not be ruled out. The Court again reiterated that although the evidence of an interested witness (the brother of the deceased) cannot be said to be inherently unreliable, it calls for more caution and circumspection. Finally, the Supreme Court held that the prosecution witnesses' testimonies did not command confidence.

The Supreme Court allowed the appeal, reversed the High Court's judgments and those of the trial court, and acquitted Aslam alias Imran of the offense under Section 302 of the IPC.

The Apex Court held that serious doubts raised as to the honesty of the prosecution witnesses, as also the suspicion of false implication by reason of pre-existing animosity, were sufficient to incline the mind of the court to give the appellant the benefit of doubt. The appellant being already on bail, his sureties were discharged.

CORAM: JUSTICE B.R. GAVAI & JUSTICE AUGUSTINE GEORGE MASIH
BETWEEN: ASLAM ALIAS IMRAN VS THE STATE OF MADHYA PRADESH 2025 INSC 403
DATE OF JUDGMENT: 27-03-2025