Supreme Court acquits accused in murder case based on unreliable eyewitness testimony: Vinobhai vs. State of Kerala (29 January 2025)

Date of the Judgment: 29 January 2025
Citation: 2025 INSC 119
Judges: Abhay S. Oka, J. and Ujjal Bhuyan, J.
Can a conviction for murder stand when the eyewitness accounts are riddled with inconsistencies and omissions? The Supreme Court of India recently addressed this critical question in a criminal appeal, ultimately acquitting the accused. This case highlights the importance of credible eyewitness testimony in criminal trials. The bench, consisting of Justices Abhay S. Oka and Ujjal Bhuyan, delivered a unanimous judgment.

Case Background

The case revolves around the alleged murder of Ramakrishnan. The prosecution claimed that on December 31, 2010, at approximately 11:45 am, the appellant, Vinobhai, fatally stabbed Ramakrishnan with a knife. The prosecution argued that a prior enmity existed between Vinobhai and the deceased because Ramakrishnan was allegedly involved in the murder of Vinobhai’s elder brother. The Trial Court convicted Vinobhai under Section 302 of the Indian Penal Code, 1860, sentencing him to life imprisonment and a fine. The High Court of Kerala upheld this conviction.

Timeline

Course of Proceedings

The Trial Court found Vinobhai guilty of murder and sentenced him to life imprisonment. The High Court of Kerala upheld this decision. Subsequently, Vinobhai appealed to the Supreme Court of India, challenging the conviction and sentence.

Legal Framework

The primary legal provision in this case is Section 302 of the Indian Penal Code, 1860, which deals with the punishment for murder. The section states:

“Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”

Additionally, Section 27 of the Indian Evidence Act, 1872, concerning the discovery of facts based on information received from an accused, is also relevant.

Section 162 of the Code of Criminal Procedure, 1973, which deals with statements to police not to be signed, use of such statements in evidence, is also relevant in this case.

Arguments

The appellant’s counsel argued that the conviction was primarily based on the testimonies of two eyewitnesses, Shaju (PW-4) and Suresh (PW-5). The counsel pointed out several inconsistencies and omissions in their statements. For example, PW-4’s claim of seeing the appellant inflict two to three stabs was not recorded in his police statement. Also, PW-4’s statement regarding his distance from the incident was also an omission. The counsel also highlighted that other potential eyewitnesses were not examined.

The respondent-State of Kerala argued that the testimonies of PW-4 and PW-5 were consistent in their core narrative. They contended that minor omissions and contradictions should not discredit the entire prosecution story. The State relied on the judgment in Edakkandi Dineshan alias P. Dineshan & Ors. v. State of Kerala [2025 SCC OnLine SC 28], to support their argument that the evidence of the eyewitnesses were credible. The State also emphasized the recovery of the weapon and bloodstained clothes at the instance of the appellant.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues. However, the core issue was:

• Whether the conviction of the appellant based on the testimonies of PW-4 and PW-5 can be sustained given the material omissions and inconsistencies in their evidence.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

✓ Edakkandi Dineshan alias P. Dineshan & Ors. v. State of Kerala [2025 SCC OnLine SC 28], Supreme Court of India: The State relied on this case to argue that minor inconsistencies in eyewitness testimony should not discredit the entire prosecution story.

✓ Manoj Kumar Soni v. State of M.P [2023 SCC OnLine SC 984], Supreme Court of India: The Court relied on this case to determine the evidentiary value of recovery made under Section 27 of the Indian Evidence Act, 1872 and held that disclosure statements alone are not sufficient for conviction.

✓ Section 27 of the Indian Evidence Act, 1872: This section deals with the discovery of facts based on information received from an accused. The Court considered the evidentiary value of the recovery of the knife at the instance of the appellant.

✓ Section 162 of the Code of Criminal Procedure, 1973: This section deals with statements to police not to be signed, use of such statements in evidence. The Court considered the omissions in the statements of the witnesses.

Judgment

The Supreme Court analyzed the testimonies of PW-4 and PW-5. The Court noted several material omissions and inconsistencies. PW-4 did not mention the number of stabs in his police statement. Also, PW-4’s statement regarding his distance from the incident was an omission. PW-5’s statement that PW-4 was present at the scene was also an omission. These omissions, along with the witnesses’ failure to report the incident or take the deceased to the hospital, made their testimonies unreliable.

The Court also considered the recovery of the knife at the appellant’s instance. However, relying on Manoj Kumar Soni v. State of M.P [2023 SCC OnLine SC 984], the Court held that disclosure statements alone are insufficient for conviction. The Court emphasized that the recovery of the weapon, without credible eyewitness testimony, could not establish guilt beyond a reasonable doubt.

The Court stated, “A doubt looms: can disclosure statements per se, unaccompanied by any supporting evidence, be deemed adequate to secure a conviction? We find it implausible.”

The Court further stated, “Although disclosure statements hold significance as a contributing factor in unriddling a case, in our opinion, they are not so strong a piece of evidence sufficient on its own and without anything more to bring home the charges beyond reasonable doubt.”

The Court also observed, “In this case, there are material omissions which amount to contradiction. Coupled with the material omissions, if we consider the conduct of both the witnesses, their version does not inspire confidence.”

Therefore, the Supreme Court acquitted the appellant, setting aside the judgments of the High Court of Kerala and the Trial Court.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the unreliability of the eyewitness testimonies. The material omissions, inconsistencies, and the unnatural conduct of the witnesses weighed heavily against the prosecution’s case. The Court also emphasized that the recovery of the weapon alone was insufficient to establish guilt beyond a reasonable doubt. The lack of credible eyewitness evidence was the critical factor in the Court’s decision to acquit the appellant.

Logical Reasoning

Key Takeaways

• ✓ Eyewitness testimony must be consistent and credible to support a conviction.
• ✓ Material omissions and inconsistencies can render eyewitness testimony unreliable.
• ✓ The recovery of a weapon alone is insufficient to prove guilt beyond a reasonable doubt.
• ✓ The conduct of witnesses, including their actions after the incident, can impact their credibility.
• ✓ Disclosure statements alone are not sufficient for conviction.

Directions

The Supreme Court directed that the appellant be set at liberty forthwith unless required in connection with any other case.

Development of Law

The ratio decidendi of this case is that a conviction cannot be solely based on unreliable eyewitness testimony and recovery of weapon. The Court emphasized that material omissions and inconsistencies in eyewitness accounts can render them unreliable. This judgment reinforces the principle that the prosecution must prove guilt beyond a reasonable doubt, and mere recovery of a weapon is not sufficient for conviction. This case also clarifies that disclosure statements alone are insufficient for conviction.

Conclusion

The Supreme Court’s decision in Vinobhai v. State of Kerala underscores the critical importance of credible eyewitness testimony in criminal trials. The Court’s analysis of the material omissions and inconsistencies in the testimonies of PW-4 and PW-5, along with the insufficient evidence from the weapon recovery, led to the acquittal of the appellant. This judgment serves as a reminder that convictions must be based on solid evidence that proves guilt beyond a reasonable doubt.

Category

Parent Category: Indian Penal Code, 1860
Child Category: Section 302, Indian Penal Code, 1860

Parent Category: Criminal Procedure Code, 1973
Child Category: Section 162, Criminal Procedure Code, 1973

Parent Category: Indian Evidence Act, 1872
Child Category: Section 27, Indian Evidence Act, 1872

Parent Category: Criminal Law
Child Category: Murder

Parent Category: Evidence Law
Child Category: Eyewitness Testimony

Parent Category: Evidence Law
Child Category: Recovery of Weapon

FAQ

Q: What was the main issue in the Vinobhai vs. State of Kerala case?
A: The main issue was whether the conviction of the appellant for murder could be sustained based on the testimonies of two eyewitnesses, given the material omissions and inconsistencies in their statements.

Q: Why did the Supreme Court acquit the accused?
A: The Supreme Court acquitted the accused because the eyewitness testimonies were found to be unreliable due to material omissions and inconsistencies. Additionally, the recovery of the weapon alone was deemed insufficient to prove guilt beyond a reasonable doubt.

Q: What are material omissions in eyewitness testimony?
A: Material omissions are significant details that are left out of a witness’s statement to the police or court. These omissions can cast doubt on the witness’s credibility and the accuracy of their testimony.

Q: Can a conviction be based solely on the recovery of a weapon?
A: No, according to the Supreme Court, the recovery of a weapon alone is not sufficient to prove guilt beyond a reasonable doubt. There must be other credible evidence, such as reliable eyewitness testimony, to support a conviction.

Q: What does the judgment mean for future cases?
A: This judgment emphasizes the importance of credible eyewitness testimony and the need for thorough investigation in criminal cases. It also clarifies that disclosure statements alone are insufficient for conviction.