Material contradiction between eyewitness testimony and medical evidence warrants benefit of doubt.

On 24 January 1984, Ramchandra was allegedly attacked near his tea shop by Sant Ram, Ram Lal, Hukumat, Dataram and Pacchoo.

According to the written report lodged by Dallu (PW-1), the accused first fired at Ramchandra, causing him to fall, and thereafter assaulted him with knives and spears; Sant Ram allegedly inflicted the fatal neck injury.

The post-mortem examination found 25 ante-mortem injuries, principally incised wounds, but no firearm or spear injury; death was attributed to shock and haemorrhage.

The prosecution relied principally on Dallu (PW-1) and Natthu Lal (PW-2) as eyewitnesses, along with Ballo (PW-4), the deceased’s widow, and formal witnesses.

The Trial Court acquitted Hukumat, Dataram and Pacchoo but convicted Sant Ram and Ram Lal under Section 302 IPC and sentenced them to life imprisonment.

The appellants challenged the conviction, contending that the eyewitness account was contradicted by the medical evidence and that they had been falsely implicated due to prior enmity.

1. Whether the testimonies of Dallu (PW-1) and Natthu Lal (PW-2) were reliable eyewitness accounts when their version regarding firing and spear assaults was inconsistent with the post-mortem findings?

2. Whether the prosecution proved the appellants’ guilt under Section 302 IPC beyond reasonable doubt, or whether the doubtful genesis and manner of the occurrence entitled them to the benefit of doubt?

3. Whether prior enmity between Sant Ram and the deceased could, by itself, sustain the conviction?

The Court considered Sections 147, 148, 149 and 302 IPC, including the ingredients of murder and unlawful assembly liability.

It applied the settled criminal-law principle that the prosecution must establish guilt beyond reasonable doubt and that suspicion, however strong, cannot substitute legally admissible proof, relying on Sujit Biswas v. State of Assam, (2013) 12 SCC 406.

It further relied on Pankaj v. State of Rajasthan, (2016) 16 SCC 192, for the rule that where the genesis and manner of the occurrence are doubtful, conviction cannot safely rest on such evidence.

The Court also applied the principle from Sushil v. State of Uttar Pradesh, 1995 SCC (Cri) 388, and State of Punjab v. Sucha Singh, (2003) 3 SCC 153, that enmity is a “double-edged weapon”: it may furnish a motive for the crime as well as a motive for false implication.

The Court found a material contradiction between the prosecution narrative and the medical evidence.

Both PW-1 and PW-2 stated that the accused fired at the deceased and assaulted him with spears before using knives, yet the post-mortem report recorded only incised wounds and one abrasion, with no firearm, pellet or spear injury.

This inconsistency was treated not as a minor discrepancy but as a circumstance undermining the witnesses’ presence and credibility, leading the Court to infer that they may have reached the spot after the occurrence and later been projected as eyewitnesses.

The Court additionally noted PW-1’s admission that he suffered from cataract and viewed the incident from approximately 20–22 paces during a winter morning, which further weakened the reliability of his identification and account.

Although prior enmity was established through earlier criminal proceedings and an NCR involving Sant Ram and the deceased’s wife, the Court held that such enmity could not replace substantive proof of participation in the murder.

Since the prosecution’s primary evidence was unreliable and the genesis and manner of the incident were doubtful, the benefit of reasonable doubt had to go to the appellants.

The eyewitness testimonies were unreliable because they materially conflicted with the medical evidence, and the prior enmity was insufficient to sustain conviction.

The appeal was accordingly allowed, the judgment of conviction and sentence dated 2 August 1984 was set aside, and Sant Ram and Ram Lal were acquitted.

As they were already on bail, they were not required to surrender; their bail bonds were cancelled and sureties discharged.

The Amicus Curiae was directed to be paid ₹15,000 for his assistance.