Murder Conviction Overturned: Supreme Court Acquits Accused Due to Unreliable Eyewitness Testimony

The case of Amar Singh v. The State (NCT of Delhi) involves an appeal against the conviction under Section 302 IPC read with Section 34 IPC. The appellants, Amar Singh and Inderjeet Singh, were sentenced to life imprisonment for the murder of Devinder Singh @ Ladi. Inderjeet Singh was also convicted under Section 27 of the Arms Act. The Supreme Court examined whether the prosecution had established guilt beyond a reasonable doubt and whether the conviction was based on reliable evidence.

Background of the Case

The prosecution’s case was that on August 3, 1990, at around 10:00 PM, the deceased, Devinder Singh @ Ladi, was walking towards a taxi stand in Sukhdev Market, Delhi, along with his brothers Amar Singh and Parminder Singh. The accused, armed with a knife and hockey sticks, allegedly attacked Devinder Singh, causing multiple fatal injuries.

The incident was reported by Parminder Singh, who claimed to have witnessed the attack along with another witness, Sujan Singh. The First Information Report (FIR) was registered, and the police recovered blood-stained weapons from the accused. The prosecution relied on eyewitness testimonies, forensic evidence, and medical reports to prove its case.

Legal Issues Raised

• Whether the eyewitness testimony was credible and reliable.
• Whether the medical evidence supported the prosecution’s case.
• Whether the prosecution had proved the guilt of the accused beyond a reasonable doubt.
• Whether there were procedural lapses that affected the fairness of the trial.

Arguments by the Petitioner

The appellants contended:

• The prosecution’s case relied heavily on the testimony of Parminder Singh, the brother of the deceased, who was an interested witness.
• The other two eyewitnesses, Amar Singh and Sujan Singh, turned hostile and did not support the prosecution’s case.
• The medical evidence did not corroborate the alleged sequence of events.
• The knife recovered had a blunt tip, making it unlikely to have caused the deep stab wounds observed in the post-mortem.
• There was an unexplained delay in lodging the FIR and in sending it to the magistrate.

Arguments by the Respondent

The State of Delhi argued:

• The conviction was based on the eyewitness testimony of Parminder Singh, who was present at the scene.
• The injuries described in the post-mortem were consistent with the attack described by the witness.
• The accused had a clear motive, as the deceased was accused in the murder of Inderjeet Singh’s father.
• The forensic evidence, including blood-stained weapons recovered from the accused, supported the prosecution’s case.

Supreme Court’s Observations

1. Reliability of Eyewitness Testimony

The Supreme Court noted that two of the three alleged eyewitnesses turned hostile and did not support the prosecution’s case. The only remaining witness, Parminder Singh, was the deceased’s brother, making him an interested witness. The Court observed:

“The testimony of an interested witness must be scrutinized with greater care. The sole eyewitness account, when unsupported by independent evidence, must inspire confidence to sustain a conviction.”

The Court found several inconsistencies in Parminder Singh’s testimony and noted that his conduct after the attack was unnatural. For example, he did not take the injured brother to a nearby clinic or call for immediate help.

2. Discrepancies in Medical Evidence

The post-mortem report listed 15 injuries, including multiple stab wounds and blunt force injuries. The forensic expert stated that injuries No. 11 and 14 were sufficient to cause death. However, the knife recovered from Inderjeet Singh had a blunt tip, raising doubts about whether it could have caused the deep stab wounds.

The Court observed:

“The prosecution failed to obtain the opinion of the forensic expert on whether the injuries could have been caused by the recovered knife. This omission casts doubt on the reliability of the prosecution’s case.”

3. Delay in FIR and Procedural Lapses

The FIR was registered at 11:00 PM, but there was a delay in sending it to the magistrate. The Court cited State of Andhra Pradesh v. M. Madhusudhan Rao, which held that an unexplained delay in sending an FIR weakens the prosecution’s case.

The Court noted:

“The delay in lodging the FIR, coupled with inconsistencies in witness statements and medical evidence, creates serious doubts about the prosecution’s case.”

4. Motive and False Implication

The prosecution argued that the accused had a strong motive since the deceased was accused in the murder of Inderjeet Singh’s father. However, the Court observed:

“Motive alone cannot substitute for proof. The prosecution must establish guilt beyond a reasonable doubt, which it has failed to do in this case.”

Final Verdict

The Supreme Court allowed the appeals and acquitted the accused, ruling that:

• The prosecution failed to prove its case beyond a reasonable doubt.
• The eyewitness testimony was unreliable and uncorroborated.
• The medical evidence did not support the prosecution’s narrative.
• The knife recovered did not match the injuries sustained by the deceased.
• There were significant procedural lapses in the investigation.

Implications of the Judgment

This ruling reinforces several legal principles:

• Eyewitness testimony must be scrutinized carefully, especially if the witness is interested.
• Medical evidence must align with the prosecution’s version of events.
• Unexplained delays in FIR registration can weaken the prosecution’s case.
• The prosecution must prove guilt beyond a reasonable doubt; motive alone is insufficient.

The judgment underscores the need for fair trials based on strong and consistent evidence, ensuring that wrongful convictions are prevented.

Petitioner Name: Amar Singh & Inderjeet Singh.
Respondent Name: State (NCT of Delhi).
Judgment By: Justice Sanjay Kishan Kaul, Justice Aniruddha Bose, Justice Krishna Murari.
Place Of Incident: Delhi.
Judgment Date: 12-10-2020.

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