Introduction

The case of Amar Singh (S) v. State (NCT of Delhi) (S). (2020 INSC 587) deliberated on the conviction of the appellants under Section 302 IPC read with Section 34 IPC for murder. The Supreme Court of India, delivered by Justice Krishna Murari, reviewed the High Court's dismissal of the criminal appeal filed by the appellants. The central issues revolved around the reliability of eyewitness testimony, the absence of corroborative evidence, and procedural lapses during the investigation.

The key parties involved were Amar Singh and Inderjeet Singh as appellants, and the State of NCT of Delhi as the respondent. The prosecution's case was primarily built on the testimony of a sole eyewitness, Parminder Singh (PW 1), whose credibility was later questioned by the Supreme Court.

Summary of the Judgment

The Supreme Court reviewed the conviction rendered by the High Court, which itself had upheld the trial court's decision to convict the appellants based on the testimony of PW 1. The High Court found no infirmity in the lower courts' judgments and dismissed the appeal. However, upon scrutiny, the Supreme Court identified significant doubts regarding the reliability of PW 1's testimony, the absence of corroborative evidence, and discrepancies in the medical reports aligning with the prosecution's narrative.

Consequently, the Supreme Court set aside the orders of the lower courts, determined that the prosecution failed to establish the guilt of the accused beyond a reasonable doubt, and directed the immediate release of the appellants unless they were required in another case.

Analysis

Precedents Cited

The judgment extensively referenced several landmark cases that underscore the principles governing the evaluation of eyewitness testimony and the necessity for corroborative evidence:

• Sunil Kumar v. State Govt. Of Nct Of Delhi (2003) 11 SCC 367: Emphasized that evidence should have a "ring of truth" and be credible and trustworthy.
• Kartarey v. State of U.P. (1976) 1 SCC 172: Highlighted the importance of presenting the alleged weapon to medical witnesses to verify if the injuries align with the weapon used.
• Ishwar Singh v. State Of U.P. (1976) 4 SCC 355: Reinforced the duty of the prosecution to ensure medical witnesses examine the alleged weapon.
• Mitter Sen v. State of U.P. (1976) 1 SCC 723: Asserted that discrepancies in vital aspects of the prosecution case necessitate skepticism towards eyewitness testimony.
• Selvaraj v. State of T.N. (1976) 4 SCC 343: Affirmed that improbable prosecution narratives, especially those supported by inconsistent eyewitness accounts, warrant setting aside convictions.

Legal Reasoning

The Supreme Court's legal reasoning focused on the foundational principles of criminal jurisprudence, particularly the need for evidence to be both credible and corroborated where doubts exist. The court analyzed:

• Sole Eyewitness Reliance: While the Evidence Act permits conviction based on a single reliable eyewitness, the court scrutinized the credibility of PW 1, considering his unnatural conduct post-incident.
• Hostile Witnesses: The other eyewitnesses, Amar Singh PW 11 and Sujan Singh PW 5, had turned hostile, undermining the prosecution's case and isolating PW 1's testimony.
• Contradictory Medical Evidence: Discrepancies between the nature of injuries and the recovered blunt knife raised questions about the prosecution's narrative.
• Procedural Lapses: Delays in filing the FIR and inconsistencies in the Medical Legal Certificate (MLC) further eroded the prosecution's case.
• Behavioral Analysis: The court highlighted the unnatural behavior of the eyewitnesses, particularly their inaction to seek immediate medical aid for the injured brother, casting doubt on their presence and credibility at the time of the incident.

Impact

This judgment reinforces the judiciary's stance on ensuring that convictions, especially in serious offenses like murder, are grounded on robust and corroborative evidence. It serves as a cautionary tale for:

• Prosecutors: To meticulously gather and corroborate evidence beyond eyewitness testimony to avoid wrongful convictions.
• Investigative Agencies: To adhere strictly to procedural norms, ensuring timely and accurate reporting and preservation of evidence.
• Defense Attorneys: To effectively challenge the credibility of sole eyewitnesses and highlight any procedural lapses.
• Judiciary: To uphold the sanctity of fair trial by critically evaluating the reliability of evidence presented.

Complex Concepts Simplified

Section 302 IPC r/w Section 34 IPC

- Section 302 IPC: Pertains to punishment for murder, which can result in life imprisonment or the death penalty.

- Section 34 IPC: Applies when a criminal act is done by several persons simultaneously, with a common intention to carry it out, making each participant liable for the same offense.

Corroborative Evidence

Evidence that supports and confirms other evidence presented, strengthening the overall case. In this judgment, the lack of corroborative evidence made the sole eyewitness's testimony insufficient for a conviction.

Hostile Witness

A witness who is uncooperative or whose testimony is adverse to the party that called them. In this case, two of the prosecution's eyewitnesses turned hostile, weakening the prosecution's case.

Medical Legal Certificate (MLC)

A document prepared by a medical professional detailing the injuries sustained by a victim, crucial for establishing the cause and manner of death. Discrepancies in the MLC raised doubts about the prosecution's narrative.

Conclusion

The Supreme Court's judgment in Amar Singh (S) v. State (NCT of Delhi) (S). (2020 INSC 587) underscores the paramount importance of credible and corroborative evidence in criminal convictions. By meticulously dissecting the weaknesses in the prosecution's case—particularly the dubious reliability of the sole eyewitness and the absence of supporting evidence—the Court reaffirmed the foundational legal principle that no individual should be convicted without incontrovertible proof of guilt. This landmark decision not only safeguards against potential miscarriages of justice but also reinforces the necessity for law enforcement and judicial bodies to uphold rigorous standards in evidence evaluation, ensuring that convictions are both fair and just.