Reliable sole eyewitness testimony corroborated by medical evidence outweighs investigative lapses in sustaining murder conviction.

On October 7, 1996, at approximately 12:00 PM, the deceased, Chandlal Manjhi, was having a meal in his courtyard

The appellant’s wife, who resided in the same house, sat beside the deceased to converse

Upon seeing them together, the appellant, who was lying in an adjoining room, fetched a katra (a goat-cutting weapon) and repeatedly struck the deceased on the head, resulting in instantaneous death

The informant (PW-6), the deceased’s daughter-in-law, witnessed the assault and raised an alarm, leading to the appellant being apprehended by villagers while attempting to flee

The Trial Court (Sessions Judge, Dhanbad) convicted the appellant under Section 302 of the IPC on April 29, 1998, and sentenced him to rigorous imprisonment for life

The appellant challenged the conviction on grounds of being based on a sole eyewitness, hostile seizure witnesses, and a perfunctory investigation

1. Whether the evidence of seizure list witnesses should be discarded in its entirety solely because they were declared hostile

2. Whether the testimony of the informant (PW-6) as a sole eyewitness is sufficiently trustworthy and reliable to sustain a conviction under Section 302 IPC

3. Whether the offence should be mitigated from Section 302 to Section 304 Part-I of the IPC on the grounds of sudden provocation and lack of premeditation

4. Whether lapses in the investigation, such as the failure to conduct chemical analysis on the weapon and blood-stained soil, vitiate the prosecution’s case

The Court applied Section 302 (Murder) and Section 300 (Exceptions to Murder) of the IPC, noting that for a case to fall under Section 304 Part-I, it must satisfy one of the exceptions in Section 300, such as sudden provocation or a sudden fight without premeditation

It relied on Section 134 of the Evidence Act, which stipulates that no particular number of witnesses is required to prove a fact, emphasizing the quality over quantity of evidence

Regarding hostile witnesses, the Court applied principles from Attar Singh v. State of Maharashtra and Neeraj Dutta v. State (NCT of Delhi), holding that testimony is not discarded in toto if corroborated by other reliable evidence

For defective investigation, it followed Karnel Singh v. State of M.P. and Ashok Kumar Singh Chandel v. State of U.P., establishing that perfunctory investigation does not warrant acquittal if credible eyewitness testimony exists

The Court found that although seizure witnesses (PW-2, PW-3, and PW-8) turned hostile, they admitted their signatures on the seizure lists, thereby corroborating the recovery of the weapon and blood-stained soil

Regarding the sole eyewitness (PW-6), the Court deemed her testimony "sterling" as it was consistent, natural, and corroborated by the medical evidence (PW-9), which confirmed four incised wounds caused by a sharp weapon like a katra

The Court rejected the plea for mitigation to Section 304 Part-I, reasoning that the appellant's act of going into a room to fetch a weapon after seeing his wife with the deceased demonstrated premeditation and an intention to kill, rather than a sudden loss of self-control

Finally, the Court held that while the Investigating Officer’s failure to send exhibits for chemical analysis was a lapse, it could not override the reliable ocular and medical evidence

The Court held that the prosecution proved the charge under Section 302 IPC beyond a reasonable doubt

The appeal was dismissed, the judgment of conviction and order of sentence were upheld, the appellant’s bail bond was cancelled, and he was directed to surrender to serve the remainder of his life sentence