Reliability of solitary eye witness testimony sufficient for conviction under Section 302 IPC despite disintegrated blood on weapon.

The appellant was convicted by the Sessions Judge, Bhopal, on August 21, 2012, for murder (Section 302 IPC), concealing evidence (Section 201 IPC), and possession of an illegal weapon (Section 25(1-B) Arms Act)

On October 31, 2010, the appellant was seen by complainant Dinesh Pal (PW-3) at Hawkers Corner, Bhopal, approaching the deceased (Mannu) with an arm around his neck

Following a brief altercation, the appellant produced a knife and inflicted multiple fatal stabs upon the deceased

The appellant fled the scene, and the deceased was declared dead upon arrival at the hospital

The appellant challenged the conviction on the grounds that the incident was a "sudden altercation" without intent, the FSL report for the weapon was inconclusive regarding human blood, and witness testimonies were unreliable

1. Whether a conviction under Section 302 IPC can be sustained based on the testimony of a solitary reliable eye witness despite a negative FSL report for human blood on the weapon.

2. Whether the act of the appellant qualifies under Exception 4 of Section 300 IPC (sudden fight/altercation) to warrant a reduction of the charge to Section 304 IPC.

Section 302 of the IPC regarding murder

Section 134 of the Indian Evidence Act, 1872, which stipulates that no particular number of witnesses is required for the proof of any fact, emphasizing that "evidence has to be weighed and not counted"

Vadi Velu Thevar and another v. State of Madras (1957), which established that a court can record a conviction based on the testimony of a single "wholly reliable" witness

Amar Singh v. State (NCT of Delhi) (2020) to affirm that corroboration is unnecessary if the sole eye witness is credible

The Court rejected the appellant's argument of a "sudden altercation," noting that the medical evidence (Ex.P/1) revealed seven distinct injuries, including a 15cm deep penetrating wound that ruptured the lung and heart

Such brutality indicated a "well-thought-out strategy" rather than a single blow in the heat of passion

Regarding the FSL report (Ex.P/26), the Court held that while human blood could not be specifically detected due to disintegration, the presence of blood on the recovered knife and the medical query report (Ex.P/28) confirming the weapon could cause such injuries supported the prosecution

Most pivotally, the Court found the testimony of Dinesh Pal (PW-3) to be "wholly reliable" and "unrebutted," as he clearly described the appellant pushing the deceased before stabbing him without any prior scuffle

Under Section 134 of the Evidence Act, the Court determined that the quality of this solitary testimony was sufficient to sustain the conviction

The Court dismissed the appeal and upheld the judgment of the Sessions Court, confirming the sentence of life imprisonment under Section 302 IPC, three years under Section 201 IPC, and two years under Section 25(1-B) of the Arms Act