Latest JudgementIndian Penal Code, 1860
Baban Shankar Daphal & Ors. vs. The State of Maharashtra, 2015
Legal distinction between an “interested” witness and a “related” witness
Supreme Court of India·22 January 2025

Indian Penal Code, 1860
Judgement Details
Court
Supreme Court of India
Date of Decision
22 January 2025
Judges
Justices Vikram Nath ⦁ Prasanna B. Varale
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
- The appellants were convicted of murder based on the allegation that they attacked the deceased, who had a property dispute with them, leading to the victim’s death due to severe injuries.
- The Trial Court initially acquitted all the accused, concluding that the eyewitness testimonies were unreliable and pointing out discrepancies between the medical evidence and the witnesses' accounts. The key inconsistency was that the eyewitnesses claimed the victim had been struck multiple times on the head, but this detail was not reflected in the medical report.
- The High Court reversed the acquittal, finding that the trial court had placed undue weight on minor inconsistencies and had failed to appreciate the overall credibility of the eyewitnesses.
- Aggrieved by the High Court’s ruling, the appellants approached the Supreme Court for redressal.
Issues
- Whether the testimonies of eyewitnesses, particularly close relatives of the victim, should be discarded solely due to their relationship with the deceased?
- Whether minor discrepancies between eyewitness testimonies and medical evidence are sufficient to render the testimonies unreliable and lead to acquittal?
- The extent to which the consistency of eyewitness testimonies should be assessed when they conflict with the medical report?
- The Court explored the legal distinction between an “interested” witness (who has a personal stake in the outcome) and a “related” witness (a close relative with no stake other than being a witness to the incident)?
Held
- The Court differentiated between "interested" witnesses (who have a personal stake in the case’s outcome) and "related" witnesses (who are merely close to the victim but do not have a motive to fabricate evidence). It emphasized that a witness's relationship to the victim does not automatically make their testimony unreliable.
- The Court acknowledged the minor inconsistencies between the eyewitness statements and the medical report but pointed out that such inconsistencies do not render the testimonies untrustworthy if the core facts of the case remain consistent. The credibility of the overall evidence must be assessed, not just isolated inconsistencies.
- Furthermore, the Court reiterated the legal principle that the testimony of eyewitnesses can still be reliable, even in the presence of minor contradictions, as long as their version of the facts holds up under scrutiny.
- The Court also stressed the need for cogent evidence and noted that hypothetical inconsistencies or conjectures should not be used to acquit the accused when the evidence, taken as a whole, points to their guilt beyond reasonable doubt.
Analysis
The judgement clarified the applicability of following provisions:
- This decision strengthens the position of eyewitnesses in criminal cases, particularly relatives of the victims, ensuring that their testimony is not automatically disqualified due to their relationship with the deceased.
- The Court's emphasis on minor contradictions not being enough to discredit entire testimonies clarifies how evidence should be approached in murder trials and similar cases.
- The judgment protects the rights of victims' families by ensuring that their testimonies are considered seriously, despite potential personal connections to the case.
- The Court ensured fair trial principles by emphasizing that evidence should be judged in its entirety and not on individual discrepancies.
- The ruling has a significant societal impact in ensuring that justice is not denied simply due to a witness’s familial ties to the victim. This could promote confidence in the justice system, especially for those who may fear their testimonies would be automatically disregarded due to their close relationship with the victim.
- It also sets a clear precedent on how courts should treat inconsistent evidence in criminal trials, ensuring that the truth-seeking process is not hindered by minor errors in testimony.