In Saheb vs. The State of Maharashtra, the Supreme Court overturned murder convictions, emphasizing that acquittals are warranted when eyewitness testimony lacks reliability and consistency.

Supreme Court Acquited two persons in murder case, both of whom were convicted of murder and sentenced to life imprisonment by lower court and upholded by the Bombay High Court. The Apex Court found that the High Court had relied too heavily on the testimony of a single eyewitness, whose account was riddled with inconsistencies and lacked corroboration., Criticized Lower Court's Reliance on Shaky Eyewitness Testimony as the Court determined that the sole evidence linking the appellants to the crime—the testimony of the victim's widow, Janakibai—was unreliable due to numerous inconsistencies.

Background: The case stemmed from the murder of Madhavrao Krishnaji Gabare at his home in Village Singi on April 8, 2006. The prosecution alleged that the appellants, along with several others, attacked Gabare and his family with axes and sticks. The alleged motive was political rivalry stemming from Gabare's previous role as the Village Sarpanch. The Trial Court convicted nine of the accused, including the appellants, but the High Court acquitted six, finding insufficient evidence to connect them to the attack. The High Court upheld the convictions of the appellants solely based on the testimony of Gabare's widow, Janakibai.

The Supreme Court meticulously examined the evidence and highlighted several inconsistencies in Janakibai's testimony. The Court noted that the attack took place during a power outage, making it difficult for anyone to identify the assailants clearly. While Janakibai claimed there was sufficient moonlight, her claim was not supported by other evidence.

The Court pointed out contradictions between Janakibai's initial complaint to the police and her later testimony in court. Her descriptions of the sequence of events and the roles of specific individuals differed significantly between the two accounts. The Court found it implausible that Janakibai could accurately recall specific details of the attack, such as who wielded which weapon, given the chaotic nature of the incident. The Court also noted her inability to attribute any actions to one of the initial assailants, raising further doubts about her reliability.

The Court emphasized the importance of proving guilt "beyond a reasonable doubt" in criminal cases. In this case, the Court found that the prosecution had not met this standard. Janakibai's testimony, both in her initial complaint and during the trial, contained conflicting accounts of the events surrounding her husband's murder. Her descriptions of the attack's timeline, the roles of specific individuals, and even the lighting conditions on the night of the murder were inconsistent. The Court noted that these inconsistencies raised significant doubts about the reliability of her testimony, particularly given that she was the only eyewitness who placed the appellants at the scene of the crime.

This case guides us to the standard of proof required for a conviction in a criminal case, especially when relying heavily on eyewitness testimony and to whatt extent can discrepancies and inconsistencies in a witness's testimony be considered before deeming their account unreliable?

The Court held that the prosecution had failed to prove the appellants' guilt beyond a reasonable doubt and also emphasized the importance of proving guilt "beyond a reasonable doubt" in criminal cases. In this case, the Court found that the prosecution had not met this standard. Janakibai's testimony, both in her initial complaint and during the trial, contained conflicting accounts of the events surrounding her husband's murder. Placing the reliance on the case of Anand Narain Shukla vs State of MP (Click to Download) the Apex court held that "...Though the maxim ‘Falsus in uno, falsus in omnibus’ is only a rule of caution and has not assumed the status of a rule of law in the Indian context, an attempt must be made to separate truth from falsehood and where such separation is impossible, there cannot be a conviction (See Narain vs. State of M.P). We find that to be so in the case on hand.". Her descriptions of the attack's timeline, the roles of specific individuals, and even the lighting conditions on the night of the murder were inconsistent.

The Court noted that these inconsistencies raised significant doubts about the reliability of her testimony, particularly given that she was the only eyewitness who placed the appellants at the scene of the crime. While acknowledging the tragic nature of the crime, the Court stressed the paramount importance of upholding the presumption of innocence and ensuring that convictions are based on credible and reliable evidence. One of the accused, Khemaji, who was also convicted by the High Court based on Janakibai's testimony, chose not to appeal his conviction.

Coram:Justices Sanjay Kumar and Justice Aravind Kumar. Between: Saheb & another vs. The State of Maharashtra Date of Judgment: 18-09-2024