A murder conviction cannot rest on materially contradictory eyewitness testimony and doubtful recoveries.

On 14 May 2011, Suchan Mandal was fatally wounded by a sharp-edged weapon while going to seek a neighbour’s help with pulling bamboo.

His son, Jagdish Mandal (PW-4), identified Billa Yadav as the assailant and reported the incident

The Sessions Court convicted the appellant under Section 302 of the Indian Penal Code (IPC) and sentenced him to life imprisonment and a fine of ₹10,000

He appealed, challenging the reliability of the alleged eyewitnesses and the investigation, including the recovery and forensic examination of the weapon and blood-stained soil.

1. Whether the evidence of the informant and other witnesses reliably established that the appellant committed the murder.

2. Whether the conviction under Section 302 IPC could be sustained in light of the contradictions in the testimony and the deficiencies concerning recovery and forensic examination of the seized materials.

The appellant was charged and convicted under Section 302 IPC.

A criminal conviction must rest on evidence that proves guilt beyond reasonable doubt; where the evidence is materially contradictory or unreliable and does not establish the accused’s involvement, the accused is entitled to the benefit of reasonable doubt.

The Court found that PW-4’s account was not sufficiently reliable, noting the inconsistency between the allegation of prior enmity and his testimony that his father had no prior enmity with the appellant. It also found uncertainty about whether PW-1 and PW-5 witnessed the incident, and considered PW-3’s conduct and testimony doubtful, including his assertion that no one else was present.

The weapon and blood-stained soil were not sent for forensic examination; the informant’s evidence also conflicted with the investigating officer’s account concerning seizure of the soil, and the circumstances of the weapon’s recovery were unclear.

In the Court’s view, the resulting contradictions and evidentiary gaps left the prosecution case doubtful and did not safely support the conviction.

It set aside the conviction and sentence, extended the benefit of reasonable doubt, acquitted the appellant, and directed his release forthwith unless required in another case.