Wholly reliable eye-witness testimony corroborated by medical evidence sustains conviction for murder.

The Appellant was convicted by the Additional Sessions Judge, Greater Mumbai, under Section 302 of the Indian Penal Code (IPC) for the murder of Sachin Agale and sentenced to life imprisonment

On April 2, 2020, PW-8 (Sanjay Lalchand Ingale) witnessed the Appellant assaulting the deceased with an iron rod on a skywalk near Ghatkopar Railway Station

The assault was allegedly motivated by the victim's failure to provide money for the Appellant’s drug addiction

PW-8 attempted to intervene but was threatened by the Appellant

Following the incident, the victim was declared dead on arrival at Rajawadi Hospital

During the investigation, the police recovered an iron rod and a knife from the Appellant

Chemical Analysis (CA) reports confirmed human blood on the weapons and the Appellant’s clothing

The Appellant challenged the conviction, arguing that PW-8 was an unreliable witness and that the recovery of the knife was inconsistent with the ocular testimony

1. Whether the ocular testimony of a single witness (PW-8) is sufficient and reliable enough to sustain a conviction for murder under Section 302 of the IPC

2. Whether the medical evidence and circumstantial recoveries (weapons and blood-stained clothing) sufficiently corroborate the prosecution’s version of the incident

Section 302 of the IPC, which mandates punishment for murder

Vadivelu Thevar v. The State of Madras (AIR 1957 S.C. 614), which classifies witnesses into three categories: wholly reliable, wholly unreliable, and neither wholly reliable nor unreliable, asserting that a conviction can be based on the testimony of a single "wholly reliable" witness

Section 313 of the Code of Criminal Procedure (CrPC) regarding the Appellant's failure to explain incriminating circumstances

The Court dismissed the Appellant's contention that PW-8 was unreliable, categorizing him as a "wholly reliable" witness whose presence at the scene was natural

The Court noted that while PW-8’s initial testimony focused on the iron rod, the medical evidence provided by PW-7 (the autopsy surgeon) specifically linked one of the victim's injuries (Injury No. 4) to the recovered knife, thereby reconciling the ocular and medical evidence

The CA reports further linked the Appellant to the crime by identifying human blood on his clothes and the recovered weapons

The Court observed that the Appellant failed to provide any explanation for these incriminating facts during his Section 313 statement, opting instead for a bare denial

By synthesizing the consistent ocular account with the scientific and medical corroboration, the Court determined the prosecution had met the burden of proof

It affirmed the "wholly reliable" status of the eye-witness and found the medical and forensic evidence to be conclusive

The High Court dismissed the appeal and upheld the Judgment and Order of the trial court sentencing the Appellant to life imprisonment

All pending interim applications were disposed of accordingly