Supreme Court Acquits Accused in Murder Case Due to Unreliable Witness Testimony: Nagaraj Reddy vs. State of Tamil Nadu (2023) INSC 269 (21 March 2023)

Date of the Judgment: 21 March 2023
Citation: (2023) INSC 269
Judges: B.R. Gavai, J. and Vikram Nath, J.
Can a conviction for murder stand solely on the testimony of a witness who is both interested and whose account has been partially disbelieved? The Supreme Court of India recently addressed this critical question in a case involving a gruesome murder. The court overturned the conviction of an accused, emphasizing that the testimony of an interested witness requires corroboration, especially when that witness’s account has been deemed unreliable in part. This judgment underscores the principle that quality, not quantity, of evidence is paramount in criminal trials. The judgment was authored by Justice B.R. Gavai, with Justice Vikram Nath concurring.

Case Background

The case revolves around the murder of one Rajappa in Oozhiyalam village, Krishnagiri district. The deceased and the accused belonged to different communities, and tensions had been brewing between them. A self-help group, of which Rajappa’s wife was the president, had purchased land and awarded a construction contract to people from their community, which further escalated the conflict. This led to criminal cases being filed against both parties at the Bagalur Police Station. On 14th September 2004, while Rajappa and his brother Narayanappa (PW-1) were on their way to court for a hearing, they were attacked. The prosecution alleged that the accused waylaid them, threw chili powder in Rajappa’s face, and then hacked him to death. The appellant, Nagaraj Reddy, was specifically accused of throwing chili powder and delivering a fatal blow to Rajappa’s head. After the crime, the accused allegedly went to Rajappa’s house, proclaiming their actions and threatening his family. Narayanappa escaped and informed Rajappa’s wife, Radha (PW-3), about the attack. A complaint was lodged, and a case was registered against five accused persons, including Nagaraj Reddy.

Timeline

Course of Proceedings

The trial court convicted accused Nos. 1 (Nagaraj Reddy, the appellant) and 3 for offenses under Sections 302 and 341 of the Indian Penal Code, 1860, sentencing them to life imprisonment, while acquitting accused Nos. 4 to 13. The trial court primarily relied on the testimonies of PWs 1, 3, and 4 for the conviction. Aggrieved by the conviction, accused Nos. 1 and 3 appealed to the High Court of Judicature at Madras. The High Court upheld the conviction of the appellant but acquitted accused No. 3, Sridhar Reddy, citing discrepancies in the date of his arrest. The State did not appeal the acquittal of accused Nos. 4 to 13. The Supreme Court then heard the appeal of Nagaraj Reddy.

Legal Framework

The case primarily involves the following sections of the Indian Penal Code, 1860:

• Section 302, IPC: This section deals with the punishment for murder. It states, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
• Section 341, IPC: This section deals with the punishment for wrongful restraint. It states, “Whoever wrongfully restrains any person shall be punished with simple imprisonment for a term which may extend to one month, or with fine which may extend to five hundred rupees, or with both.”

Arguments

Appellant’s Arguments:

• The appellant argued that the High Court erred in convicting him under Sections 302 and 341 of the IPC.
• It was contended that the High Court’s decision was inconsistent as it acquitted accused No. 3 based on the evidence of Narayanappa (PW-1), yet convicted the appellant based on the same testimony.
• The appellant highlighted that the High Court’s reasoning for distinguishing his case from that of accused No. 3 was perfunctory.

Respondent’s Arguments:

• The respondent argued that both the trial court and the High Court had concurrently found the appellant guilty based on an appreciation of the evidence.
• It was submitted that there was no perversity in the concurrent findings of fact by the lower courts.

The core of the appellant’s argument was that if the testimony of Narayanappa (PW-1) was unreliable enough to acquit one accused, it should not be the basis for convicting another. The respondent, on the other hand, relied on the concurrent findings of the lower courts, arguing that the evidence was sufficient to establish guilt.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the conviction of the appellant could be sustained solely on the testimony of Narayanappa (PW-1), when his testimony was deemed unreliable for other accused persons.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the unreliability of the sole eyewitness, Narayanappa (PW-1). The court noted that PW-1 was an interested witness (brother of the deceased) and that his testimony had been disbelieved by the trial court and High Court in relation to other accused persons. The court emphasized that when a witness’s testimony is deemed unreliable in part, it cannot be the sole basis for a conviction without corroboration. The court also highlighted the principle that quality of evidence is more important than quantity. The court was also influenced by the fact that the High Court’s reasoning for distinguishing the case of the appellant from that of accused no. 3 was perfunctory. The court found that the conviction of the appellant was not sustainable based on the evidence on record.

The Supreme Court’s reasoning was clear: “In that view of the matter, we are of the considered opinion that the conviction could not have been based solely on the testimony of Narayanappa (PW-1), without corroboration of his testimony.” The court also noted, “We find that the reasoning given by the High Court in distinguishing the case of the present appellant as against accused No. 3 is totally perfunctory.” The court emphasized the importance of reliable evidence, stating, “it is a sound and well-established rule of law that the court is concerned with the quality and not with the quantity of the evidence necessary for proving or disproving a fact.”

The Supreme Court overturned the High Court’s decision, acquitting the appellant of all charges. The court found that the High Court’s reasoning was perfunctory and that the conviction could not be based solely on the testimony of an interested witness whose testimony had been deemed unreliable in part. The court emphasized that the quality of evidence is more important than the quantity.

Key Takeaways

• The testimony of an interested witness requires careful scrutiny and corroboration, especially if the witness’s account has been partially disbelieved.
• Courts must focus on the quality of evidence rather than the quantity.
• Perfunctory reasoning by lower courts can be overturned by the Supreme Court.
• This judgment reinforces the principle that a conviction cannot stand solely on unreliable testimony.

Directions

The Supreme Court directed that the appellant be set at liberty forthwith if not required in any other case.

Development of Law

The ratio decidendi of this case is that the testimony of an interested witness, especially when deemed unreliable in part, cannot be the sole basis for a conviction without corroboration. This judgment reinforces the principle that the quality of evidence is more important than quantity. This case does not introduce a new principle but reiterates and applies existing legal principles regarding the evaluation of evidence in criminal trials.

Conclusion

The Supreme Court’s decision in Nagaraj Reddy vs. State of Tamil Nadu underscores the importance of reliable witness testimony in criminal trials. The court acquitted the appellant, emphasizing that the testimony of an interested witness, when partially disbelieved, requires corroboration. This judgment highlights the judiciary’s commitment to ensuring that convictions are based on sound and credible evidence, rather than mere numbers of witnesses.