Four Accused Are Acquitted as Supreme Court Finds Prosecution Case Hinges on Doubtful Oral Testimony

A Constitution Bench comprising Chief Justice of India Sanjiv Khanna, Justice Sanjay Kumar and Justice K.V. Viswanathan heard appeals against convictions in a 2009 homicidal death following special leave petitions filed by four convicts. The matters arose from the conviction and life sentences imposed by the Sessions Court and upheld in part by the Madhya Pradesh High Court in a trial concerning the murder of Mohan Singh.

The Court allowed the appeals and set aside the convictions and sentences of Arun, Radheshyam, Narendra and Ramlal, holding that the prosecution failed to prove the charges beyond reasonable doubt. The Bench found that the case “hinges only upon the oral evidence of the family members of Mohan Singh” and that those testimonies were “completely untrustworthy and specious,” warranting the benefit of doubt to the appellants. The Court, in its reasoning, observed: “As matters stand, the entire case of the prosecution hinges only upon the oral evidence of the family members of Mohan Singh, the deceased. However, as already noted hereinbefore, their evidence is found to be completely untrustworthy and specious. Conviction of the appellants cannot rest solely on such doubtful testimonies. The Trial Court and the High Court erred in the appreciation of this dubious oral evidence and in drawing the proper inferences therefrom. The appellants would invariably have to be given the benefit of doubt in such circumstances, as the prosecution failed to prove the charges levelled against them beyond reasonable doubt.” The Court further noted discrepancies in timelines, delayed recording of key statements and absence of forensic linkage between the recovered weapon and the cause of death.

Background The dispute arose from the fatal attack on Mohan Singh on 06.11.2009. An FIR was registered by the deceased’s father, Devisingh, reporting that Mohan Singh was shot and his head crushed. Five men — Arun, Radheshyam, Narendra, Abhay Singh and Ramlal — were charged; Abhay was acquitted by the High Court but the remaining four were convicted for murder under Section 302 read with Section 34 IPC by the Sessions Court and their convictions were partly affirmed by the High Court on 25.01.2024. The prosecution relied principally on oral testimony of family members and a child witness, and on the recovery of a 12-bore country-made pistol allegedly from Arun.

On appeal, the Supreme Court scrutinised the reliability of the eyewitness accounts, noting material inconsistencies between the FIR and subsequent depositions, contradictory timelines about departures, tea and hair-cut timings, and substantial delays in recording statements under Section 161 Cr.P.C. The Court observed that medical evidence did not conclusively establish a gunshot as the cause of death — one wound was attributed to a stabbing weapon and no bullet was produced — undermining the evidentiary value of the weapon recovery. The Bench emphasised that while the maxim “Falsus in uno, falsus in omnibus” was at best a rule of caution, the proven contradictions and infirmities in the principal witnesses’ accounts rendered the prosecution case doubtful. The appeals were allowed; the judgments of the High Court and Sessions Court were set aside and all appellants were acquitted. Interim directions previously suspending sentences for three appellants were noted; Ramlal, who remained in custody, was ordered to be released forthwith unless detained in connection with another lawful case. Bail bonds and sureties stood discharged and any fines paid were ordered to be refunded.

Case Details: Case No.: 2025 INSC 406; Criminal Appeals arising out of SLP(Crl.) Nos. 5493/2024, 6060/2024, 8627/2024 and 8628/2024 Case Title: Arun v. State of Madhya Pradesh Appearances: For the Petitioner(s): [Not indicated in the judgment] For the Respondent(s): [Not indicated in the judgment]