New Delhi, September 20, 2023 – In a recent landmark judgmentin Rameshji Amarsingh Thakor v. State of Gujarat , the Supreme Court of India reiterated the critical significance of eyewitness accounts in criminal trials. The ruling, delivered by a bench comprising Justices Aniruddha Bose and Bela M Trivedi, drew upon the precedents set in Darbara Singh v. State of Punjab (2012) 10 SCC 476 and Anvaruddin v. Shakoor 1990 (3) SCC 266, emphasizing the paramount value of ocular evidence over the opinions of medical experts.
The case that led to this reaffirmation involved an appeal against a Gujarat High Court verdict, which had overturned the acquittal of the appellant under Section 302 of the Indian Penal Code (IPC) for the murder of Jayantibhai on July 10, 1995.
Jayantibhai’s brutal killing, attributed to the appellant, his father, and brother, formed the crux of the prosecution’s case. The key pillars of the prosecution’s argument rested on the eyewitness account of Parvatiben (PW2) and the dying declaration of the victim’s brother (PW4) and another witness (PW5).
The trial court Initially acquitted all three accused individuals, primarily relying on medical evidence. However, the Gujarat High Court reversed this decision, holding the appellant responsible for the crime. The matter eventually found its way to the Supreme Court.
Advocate Mr. D.N. Ray, representing the appellant, pointed out discrepancies in the manner in which the knife blows were alleged to have been inflicted and in the identification of the weapon used in the assault. He vehemently argued that the medical evidence strongly suggested that the knife, referred to as “muddamal 9,” could not have inflicted the fatal injury.
The Supreme Court, In its judgment, criticized the trial court’s undue emphasis on minor contradictions in witness statements while ignoring the broader testimony of prosecution witnesses. The Court held that these contradictions, including the variance in the number of injuries, should not be the sole basis for rejecting the prosecution’s case. It emphasized that eyewitnesses to a gruesome crime might not provide a blow-by-blow account akin to a screenplay.
Citing the judgment in State of H. P. v. Lekh Raj (2000) (1) SCC 247, the Court emphasized that discrepancies in witness testimonies were common and should not be used to dismiss the entire body of evidence unless they were of substantial significance.
The Court remarked, ”Trivial discrepancies ought not to obliterate an otherwise acceptable evidence… The court shall have to bear in mind that different witnesses react differently under different situations: whereas some become speechless, some start wailing while some others run away from the scene and yet there are some who may come forward with courage, conviction, and belief that the wrong should be remedied.”
In the end, the Supreme Court found that the evidence provided by eyewitnesses and post-occurrence witnesses remained consistent and sufficiently corroborated the prosecution’s narrative of events.
Consequently, the Supreme Court upheld the conviction and dismissed the appeal. It cautioned against undue reliance on fanciful doubts when considering the rule of the benefit of the doubt, citing the precedent in Gurbachan Singh v. Satpal Singh (1990).
The Court’s order stated, ”We, accordingly, dismiss this appeal. We are apprised that the appellant is on bail. His bail bond shall stand canceled, and the appellant is directed to surrender before the trial Court within a period of four weeks.”
This landmark judgment serves as a significant reminder of the judiciary’s commitment to upholding the integrity of eyewitness accounts in criminal trials and highlights the need to focus on the substance of evidence rather than minor inconsistencies.