Allahabad High Court

Testimony of alleged eyewitnesses is unreliable if their conduct is unnatural and contradictions shake the prosecution’s foundation.

Sabal Singh And 3 Others vs State Of U.P.

Allahabad High CourtJUDGMENT: July 01, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

On February 7, 2012, at 10:30 PM, the deceased (Veer Singh) was allegedly taken from his home by the appellants and assaulted with lathis and dandas, leading to his death

Source reference: p.2-3

The First Information Report (FIR) was lodged by his cousin, Sumer Singh (PW-1), on February 8, 2012, at 7:30 AM, with a delay of nine hours

Source reference: p.3, 8

The prosecution presented nine witnesses, including PW-1, PW-2 (Prabha Bai), and PW-7 (Harivansh) as eyewitnesses

Source reference: p.4-5

The Trial Court (Sessions Judge, Chitrakoot) convicted the appellants under Sections 147, 302/149, 201, and 120B of the IPC

Source reference: p.2, 5

The appellants challenged this conviction, citing material contradictions in testimony and the doubtful presence of eyewitnesses

Source reference: p.6
02

Issues

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt based on reliable eyewitness testimony.

Source reference: p.8-11

2. Whether the conduct of the prosecution witnesses and the delay in lodging the FIR rendered the prosecution's story suspicious.

Source reference: p.8, 21

3. Whether the Trial Court erred in law by failing to consider the cross-examination of witnesses during evidence appreciation.

Source reference: p.19-20
03

Law Applied

The court primarily applied Section 302 (Murder), Section 149 (Unlawful Assembly), and Section 201 (Disappearance of Evidence) of the IPC

Source reference: p.2

It relied on Section 3 of the Indian Evidence Act, 1872, emphasizing that "evidence" encompasses both examination-in-chief and cross-examination

Source reference: p.19

Furthermore, it applied the precedent established in Badam Singh v. State of Madhya Pradesh (2003), which dictates that if the conduct of witnesses is unnatural or renders the case incredible, the court may reject their testimony regardless of consistency in their initial statements

Source reference: p.18
04

Reasoning

The Court found that the Trial Court failed to appreciate evidence in its totality, focusing solely on examination-in-chief while ignoring fatal admissions in cross-examination

Source reference: p.19-20

PW-1 and PW-2 admitted in cross-examination that they searched for the deceased all night, which contradicted their claim of having seen the assault

Source reference: p.11, 13

PW-7 admitted he was not present at the spot and only testified at the behest of the prosecution years later

Source reference: p.15-16

The Court observed that the nine-hour delay in the FIR, despite the availability of transport and proximity to the police station, suggested deliberation and concoction

Source reference: p.8-9

Additionally, the Investigating Officer (PW-5) confirmed no bloodstains were found at the alleged site of the murder, supporting the probability that the deceased was killed elsewhere and the body was moved

Source reference: p.17

The conduct of the relatives—failing to seek medical aid for the deceased—was deemed unnatural and a violation of the "truthfulness" requirement for eyewitnesses

Source reference: p.8, 18
05

Holding

The Court answered the issues in the negative, holding that the prosecution failed to establish a credible chain of events or provide reliable eyewitness testimony

The High Court held that the Trial Court's judgment was perverse as it misread the evidence and ignored major contradictions

Source reference: p.6, 21

Consequently, the appeals were allowed, the conviction and sentences dated December 10, 2020, were set aside, and the appellants were acquitted of all charges

Source reference: p.21-22

Provisions of Section 437-A Cr.P.C. were directed to be complied with

Source reference: p.22
Allahabad High Court

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Sabal Singh And 3 OthersvsState Of U.P.

Allahabad High Court · July 01, 2026

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