Summary
The Supreme Court set aside the appellants’ convictions because material contradictions in the principal witnesses’ accounts left their participation unproved beyond reasonable doubt. Disputes concerned the origin of the FIR, opportunity to see the assault, identification and the roles assigned to the appellants. The medical evidence did not support the attributed fist-and-foot injuries. The Court assessed these defects cumulatively, distinguishing material contradictions from minor discrepancies and rejecting convictions founded on assumptions.
Issues
- Whether the principal witnesses reliably established the appellants’ participation.
- Whether contradictions concerned material features rather than minor details.
- Whether concurrent convictions could stand on the record.
Held
- The central witnesses differed on who lodged the report, their ability to observe the incident and the weapons or roles attributed to the appellants. A material omission concerning following the deceased to the scene further weakened the claimed eyewitness account. (¶¶ 9, 10, 11, 13, 16, 18)
- Minor inconsistencies do not justify rejecting testimony wholesale. Here the contradictions went to the prosecution’s core, and the medical evidence did not disclose the injuries attributed to fist-and-foot blows; the cumulative record failed to meet proof beyond reasonable doubt. (¶¶ 12, 13, 14, 15, 18)
- Evidence must be assessed as a whole for quality and trustworthiness rather than by counting witnesses. One unreliable account could not supply corroboration for another unreliable account, and assumptions could not replace proof. (¶¶ 16, 17, 18)
- Concurrent findings did not prevent interference where the courts below overlooked these material defects. The Supreme Court held the appellants’ guilt unproved beyond reasonable doubt and set aside the judgment sustaining their convictions. (¶¶ 6, 16, 17, 18, 19)
Result
Appeals allowed; impugned High Court judgment set aside and the appellants’ convictions overturned for failure to prove guilt beyond reasonable doubt.