Dadu @ Ankush & Anr. v. State of Madhya Pradesh & Anr., 2025
The ruling reinforces the principle that hostile witness evidence must be examined in detail, not rejected in entirety.
Judgement Details
Court
Supreme Court of India
Date of Decision
8 December 2025
Judges
Justice Dipankar Datta and Justice Augustine George Masih
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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Appellants were convicted by the Trial Court under IPC Sections 323, 354 and SC/ST Act, alleging:
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Approaching the victim at her home, pulling her dupatta, assaulting her brother, and committing acts knowing she belonged to a Scheduled Caste.
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The Madhya Pradesh High Court upheld these convictions.
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PW-4, a relative of the victim, was declared hostile by the prosecution and testified an alternate version:
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The incident occurred at a Ganesh Puja pandal following a scuffle when the victim’s brother felt the accused stepped on his feet.
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High Court refused to consider PW-4’s testimony, solely because he was hostile.
Issues
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Whether a hostile witness’s testimony can be completely rejected solely on the declaration of hostility?
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Whether truthful portions of a hostile witness’s evidence can be admitted to support either the prosecution or defense?
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Whether the High Court erred in dismissing PW-4’s testimony entirely, thereby sustaining convictions?
Held
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The Hostile witness testimony is not automatically inadmissible.
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Courts must scrutinize the evidence closely and accept parts consistent with the case of prosecution or defense.
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Convictions based on ignoring such testimony cannot be sustained.
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Supreme Court acquitted the appellants in light of PW-4’s credible and consistent account.
Analysis
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The ruling reinforces the principle that hostile witness evidence must be examined in detail, not rejected in entirety.
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Cites State of U.P. v. Ramesh Prasad Misra to clarify legal position on hostile witnesses.
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Ensures that courts do not mechanically reject testimony, which may contain valuable facts supporting defense or prosecution.
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Highlights the importance of evaluating each portion of evidence independently to prevent miscarriage of justice.
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Promotes fair trial standards by balancing the treatment of uncooperative witnesses with the rights of the accused.