Conviction on Sole Eyewitness Testimony is Sustainable if Evidence is Cogent and Inspires Confidence

The appellant, Umesh Yadav, married the deceased Sarita on 28.05.2011.

It is alleged that the appellant and his family harassed the deceased for a motorcycle.

On 10.10.2012, while the deceased was staying at her paternal home, the appellant visited and, after sending the deceased’s sister (PW-2) away on a pretext, assaulted the deceased with a knife, causing fatal injuries to her neck and lungs.

PW-2 witnessed the assault, and the informant (PW-1) lodged an FIR the same day.

The Trial Court acquitted the appellant of charges under Sections 498A, 304B IPC and the Dowry Prohibition Act but convicted him under Section 302 IPC, sentencing him to life imprisonment.

The appellant challenged this conviction on the grounds of lack of motive and reliance on a sole eye-witness.

1. Whether a conviction can be sustained based solely on the testimony of a single eye-witness (PW-2) when other family members were not present at the time of the incident?

2. Whether minor contradictions in the testimony of a witness regarding the specific room of occurrence or the exact nature of injuries are sufficient to discard their entire evidence?

3. Whether the prosecution is required to prove motive in a case of direct ocular evidence?

Section 302 of the Indian Penal Code (IPC) for the punishment of murder.

Section 134 of the Indian Evidence Act, 1872, which mandates that no particular number of witnesses is required for the proof of any fact, emphasizing the quality over quantity of evidence.

Conviction can be based on a sole reliable witness as per Sunil Kumar v. State Government of NCT of Delhi.

Minor discrepancies or "trivial matters" do not corrode the core of a witness's credibility as established in Brahm Swaroop v. State of Uttar Pradesh.

Shyam Sundar v. State of Chhattisgarh was cited to hold that variations in narrating an incident over time are natural and do not necessarily imply untruthfulness.

The Court observed that PW-2 (Anita) was a natural and reliable eye-witness, being present at the house during the morning incident.

Although there were minor discrepancies—such as whether both sisters served food or which specific room the assault occurred in—the Court held these to be "trivial" given the witness's consistency regarding the identity of the assailant and the weapon used.

The court emphasized that a witness cannot be expected to provide a "parrot-like" narration years after the event.

Regarding motive, the Court held that in a case of direct evidence where the ocular testimony is trustworthy, the absence of a proven motive is immaterial.

The medical evidence provided by PW-4 corroborated the ocular testimony, as the cause of death (shock and hemorrhage from stab wounds) aligned with the knife assault described by PW-2.

The recovery of a bloodstained knife from the site further linked the appellant to the crime.

The court dismissed the appeal, affirming the Trial Court's judgment and order dated 25.10.2019. The conviction under Section 302 IPC and the sentence of life imprisonment were upheld, and the appellant was ordered to remain in jail to serve the remainder of his sentence.