Reaffirming the Need for Credible Corroboration in Single-Eyewitness Cases

1. Introduction

The Supreme Court of India’s decision in Abdul Wahid & Anr. v. State of Rajasthan (2025 INSC 295) addresses the complexities involved when a criminal conviction relies predominantly on the testimony of a single eyewitness, especially under circumstances casting doubt on the witness’s reliability. In this particular case, the three appellants—Abdul Wahid, Babu, and Abdul Shakur—had been convicted under Sections 302/149 of the Indian Penal Code (“IPC”) by both the Trial Court and the High Court of Rajasthan for the murder of one Ahsan Ali. They appealed before the Supreme Court, contesting the validity of convictions largely based on the alleged eyewitness account of one prosecution witness.

The key legal issue revolved around whether the uncorroborated testimony of a solitary eyewitness—who was purportedly a “stock witness” for the police and who admitted to having criminal antecedents—was reliable enough to sustain a conviction for murder. Additionally, the Court addressed shortcomings in the police investigation, such as the non-seizure of vital evidence, inconsistent narratives among prosecution witnesses, and suspicious recoveries of alleged murder weapons.

Ultimately, the Supreme Court set aside the conviction and sentence, highlighting the principle that in serious criminal cases, eyewitness evidence heavily marred by inconsistencies or lacking independent corroboration may be insufficient to uphold a guilty verdict.

2. Summary of the Judgment

In Abdul Wahid & Anr. v. State of Rajasthan, the Supreme Court unanimously held that the prosecution had failed to establish the appellants’ guilt beyond reasonable doubt. After analyzing the prosecution evidence, particularly the testimony of the primary eyewitness (PW-1) and other supporting witnesses (PW-3, PW-4, among others), the Court found:

• The testimony of the principal eyewitness was riddled with inconsistencies and contained contradictions about the sequence of events, the manner of attack, and the positions of the accused.
• Other purported eyewitnesses had offered contradictory or incomplete accounts, several becoming hostile during the trial.
• The investigation itself suffered from serious lapses, particularly the failure to seize critical evidence (the motorcycle allegedly used by the victim and the eyewitness), the absence of any meaningful forensic corroboration, and heavily suspect weapon recoveries.
• Because of the cumulative effect of these evidentiary defects, the appellants were entitled to the benefit of the doubt, leading to their acquittal and the setting aside of their sentences of life imprisonment.

3. Analysis

3.1 Precedents Cited

The Court referred to and distinguished certain judicial authorities and precedents relevant to single-eyewitness testimony and the standards for assessing credibility:

1. Anil Phukan v. State of Assam (1993) 3 SCC 282: Cited by the defense to emphasize that the testimony of a sole eyewitness—particularly one with questionable antecedents—should be approached with caution and cannot form the sole basis for conviction unless it stands on firm evidentiary footing.
2. Narendrasinh Keshubhai Zala v. State of Gujarat (2023 SCC OnLine SC 284): Referenced to highlight that inconsistencies in eyewitness testimony, coupled with incomplete or flawed supporting evidence, weaken the prosecution’s case and may necessitate acquittal.
3. Indian Evidence Act, 1872, Section 27: Pertinent to the question of whether the accused’s alleged confessional statements leading to recovery of weapons were admissible or adequately corroborated. The Court found that procedural lapses and hostile seizure witnesses negated the value of these recoveries.

3.2 Legal Reasoning

The Supreme Court’s reasoning revolved around five primary points:

1. Credibility of the Sole Eyewitness: The Court scrutinized the deposition of PW-1, noting his criminal antecedents, admitted role as a police “stock witness,” and the various contradictions in his testimony. It found his evidence insufficiently reliable in the absence of corroboration from independent or neutral sources.
2. Contradictions and Inconsistencies: The pivotal witnesses gave widely differing accounts, and many prosecution witnesses were declared hostile. The Court held that such discrepancies raised serious doubts concerning the reliability of the prosecution's overall narrative.
3. Investigation Lapses: The investigative process was criticized for not seizing the deceased’s motorcycle (which was allegedly central to the incident), failing to collect and analyze blood samples from the crime scene, and presenting dubious weapons recoveries that were allegedly found in open, easily accessible places without any evidentiary continuity.
4. Medical Evidence: While the autopsy confirmed that Ahsan’s death was homicidal, the location and nature of injuries raised further doubts regarding the statements made by the eyewitness about the sequence of stabbing. No link to the accused’s weapons was established.
5. Benefit of Doubt: Considering all these factors—especially serious investigative flaws and the unreliable nature of the eyewitness testimony—the Court ruled in favor of the accused, underscoring the principle that conviction for murder requires proof beyond reasonable doubt.

3.3 Impact

• Heightened Scrutiny of Sole-Eyewitness Cases: This decision underlines that courts must exercise extreme caution when basing convictions on the testimony of a single eyewitness who may be motivated, has a criminal background, or is otherwise deemed unreliable.
• Emphasis on Corroborative Evidence: The ruling pushes prosecuting agencies to collect comprehensive and rigorous evidence—such as forensic examination, properly seizing and analyzing weapons, clothes, or blood samples from the scene—to strengthen their cases.
• Investigative Oversight: The judgment highlights the need for thorough police practices. Lack of diligence in crime scene management or in verifying the authenticity of recoveries can weaken the prosecution irretrievably.
• Upholding Procedural Fairness: In underscoring the right to a fair trial, the Court reiterates that convictions must be built on reliable and verifiable facts, not on speculation or faulty evidence.

4. Complex Concepts Simplified

Several legal and investigative concepts in the judgment can be expressed in simpler terms:

1. Single-Eyewitness Testimony: Under Indian law, one credible eyewitness can be enough to convict if the testimony is consistent and trustworthy. However, in the present case, the Court found this eyewitness’s credibility questionable and not supported by additional evidence.
2. Section 27 of the Indian Evidence Act: This provision deals with the admissibility of statements made by the accused while in custody, particularly those leading to the discovery of new facts. The Court clarifies that for such discoveries to have evidentiary value, they must be credible, properly documented, and made under conditions ensuring authenticity.
3. Hostile Witnesses: A witness becomes “hostile” when they contradict their earlier statements or the prosecution’s version, often undermining the prosecution’s narrative. In this case, many crucial witnesses changed their stance, making it harder for the prosecution to prove guilt.
4. “Benefit of the Doubt”: In criminal law, the accused must be acquitted if the prosecution does not prove guilt beyond reasonable doubt. Here, the contradictions and absent corroboration created too much uncertainty, so the appellants were given the benefit of the doubt.

5. Conclusion

The Supreme Court’s ruling in Abdul Wahid & Anr. v. State of Rajasthan reaffirms an essential safeguard in the criminal justice system—that the liberty of an individual cannot be curtailed without credible, consistent, and legally admissible evidence. While homicide remains among the gravest of crimes, the onus is on the prosecution to demonstrate the accused’s culpability through robust and thorough investigation.

By setting aside the conviction, this judgment warns against over-reliance on a solitary, uncorroborated eyewitness—especially one with a checkered history. It also signals the crucial need for investigators to gather forensic evidence and ensure procedural transparency at all stages.

Going forward, this decision will likely shape how courts assess the value of single-eyewitness testimony in the face of contradictory details and incomplete investigation. It may serve as a guiding precedent to emphasize that procedural fairness and evidentiary consistency remain cornerstones for upholding or confirming a conviction under criminal law.