HEADLINE: Testimony of Related Eyewitnesses Is Wholly Reliable if Intrinsically Trustworthy and Corroborated by Medical Evidence

On May 26, 2015, at 03:30 a.m., the appellant, Ranjeet Patel, allegedly approached his cousin Ram Asrey in a shared courtyard (sehan) and assaulted him on the head with an iron rod (sabbar/rambha) following a monetary dispute.

The assault was witnessed by the deceased’s brother (PW-1), wife (PW-2), mother (PW-3), and sister-in-law (PW-4).

Ram Asrey succumbed to head injuries before reaching BHU Hospital.

The Trial Court (Sessions Judge, Jaunpur) convicted the appellant under Section 302 IPC, sentencing him to life imprisonment.

The appellant challenged the conviction, citing the witnesses’ status as "interested relatives," minor contradictions in the description of the murder weapon, and lack of visibility at the time of the incident.

1. Whether the testimony of "interested witnesses" (close relatives) can form the sole basis for conviction without independent corroboration.

2. Whether minor contradictions regarding the nomenclature of the weapon (iron rod vs. sabbar) and the sequence of hospital/police visits vitiate the prosecution's case.

3. Whether there was sufficient visibility at 03:30 a.m. in May to reliably identify the assailant.

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

The principle that "interested" or "related" witnesses are natural witnesses whose testimony cannot be discarded solely due to relationship, provided it is scrutinized with care (Ashok Kumar Chaudhary v. State of Bihar; Namdeo v. State of Maharashtra).

The doctrine that residents of a locality/family can identify known persons even in meagre light (Nathuni Yadav v. State of Bihar).

The principle that motive loses significance in the presence of credible ocular evidence.

The Court found the ocular evidence of PW-1 to PW-4 to be "intrinsically reliable" and natural, noting that a family member is unlikely to shield the real culprit to falsely implicate another relative.

The Court dismissed the "darkness" defense, holding that at 03:30 a.m. in peak summer (May), identification is possible among close relatives through gait, speech, and proximity.

Regarding the weapon, the Court held that the distinction between an "iron rod" and a "rambha" (boring tool) is trivial as both are heavy iron objects capable of causing the fatal temporal bone fracture noted in the postmortem report (Exhibit Ka-2).

The Court observed that the appellant’s specific target (the head) demonstrated a clear intention to cause death under Section 302.

Minor discrepancies in the sequence of events (visiting the police station before or after the hospital) were deemed insufficient to shake the core of the prosecution's narrative.

The Court held that the prosecution successfully proved the charge under Section 302 IPC beyond a reasonable doubt. Consequently, the High Court dismissed the appeal and upheld the judgment and life sentence passed by the Trial Court.