Supreme Court Acquits Appellant in Murder and Attempted Murder Case Under Sections 302, 307, and 504 of Indian Penal Code, 1860 Due to Inconsistent Evidence and Lack of Reliable Testimony


CASE NOTE & SUMMARY

The Supreme Court heard an appeal against the High Court's judgment affirming the conviction of Anjani Singh for offences under Sections 302, 307, and 504 of Indian Penal Code, 1860. The prosecution alleged that on 20.10.2004, during a village function, the appellant and others attacked multiple persons, resulting in two deaths and several injuries. The Court examined the evidence, including eyewitness testimonies and medical reports, and found material inconsistencies and lack of reliability. It held that the prosecution failed to establish guilt beyond reasonable doubt, leading to the acquittal of the appellant.


HEADNOTE

Criminal Law-- Indian Penal Code, 1860-- Sections 302, 307, 504 and 34-- Murder-- Three accused were tried-- Appellant no.1 and 2 were convicted u/s 302, 307 and 504 of IPC-- Third accused was convicted u/s 302, 307, 504 and 34 of IPC- Appeal before high court filed by convicted accused-- High court confirmed the conviction of Appellant no. 1 and 2 However acquitted third accused -- Aggrieved-- Challenge to conviction before supreme court-- Incident occurred at the time of a drama was being playing during celebration of festival-- Beating to son of PW-1- Murder-- Witnesses other than PW-1 Claimed that lights went off at the time of incident-- Benefit of doubt given to third accused by high court-- Requirement of close scrutiny of testimony of PW-1-- PW-1 was already booked under Goondas Act twice in past-- PW-1 is the only eye witness who supported the case of prosecution-- Inconsistencies in the version of PW-1 with regard to place from where shots were fired-- PW-1 did not specify the role of appellant no.1-- No explanation as to why indiscriminate firing was resorted-- Doubts in the testimony of PW-1 lacking stellar quality-- Country made pistol not recovered from appellant no.1 during investigation-- Magazine recovered from the spot could not be forensically connected with seized rifle-- Except PW-1 no one supported the case of prosecution-- Benefit of doubt extended to appellant- Conviction set aside- Appeal Allowed

Para-- 26, 27, 32, 33, 34, 35, 36, 37, 38


ISSUE OF CONSIDERATION

The Issue of consideration was whether the conviction of the appellant under Sections 302, 307, and 504 of Indian Penal Code, 1860 was sustainable based on the evidence presented

FINAL DECISION

The Supreme Court allowed the appeal, set aside the conviction of Anjani Singh under Sections 302, 307, and 504 of IPC, and acquitted him of all charges

Citation: 2026 LawText (SC) (01) 2

Case Number: Criminal Appeal No. 591 of 2020

Date of Decision: 2026-01-05

Case Title: The Issue of consideration was whether the conviction of the appellant under Sections 302, 307, and 504 of Indian Penal Code, 1860 was sustainable based on the evidence presented

Before Judge: MANOJ MISRA J. , JOYMALYA BAGCHI J.

Equivalent Citations: 2026 INSC 3

Appellant: Anjani Singh

Respondent: The State of Uttar Pradesh

Nature of Litigation: Criminal appeal against conviction for murder and attempted murder

Remedy Sought: Appellant sought acquittal and setting aside of conviction

Filing Reason: Appellant aggrieved by High Court's affirmation of conviction

Previous Decisions: Trial Court convicted appellant under Sections 302, 307, and 504 of IPC -- High Court affirmed conviction but acquitted co-accused Rishabh Dev Singh

Issues: Whether the conviction of the appellant under Sections 302, 307, and 504 of IPC is sustainable based on the evidence Whether the prosecution proved guilt beyond reasonable doubt

Submissions/Arguments: Prosecution argued that eyewitnesses and medical evidence established guilt Defense argued inconsistencies in evidence and lack of reliable testimony created reasonable doubt

Ratio Decidendi: The prosecution must prove guilt beyond reasonable doubt with consistent and reliable evidence -- Inconsistencies in eyewitness testimony and lack of corroboration can lead to acquittal -- Benefit of doubt should be given to the accused when evidence is not conclusive

Judgment Excerpts: This appeal arises from judgment and order of the High Court of Judicature at Allahabad dated 05.07.2019 All three were convicted by the Court of Additional Sessions Judge On appeal to the High Court, Rishabh Dev Singh was acquitted whereas conviction of Anjani Singh and Ravindra Singh was affirmed The prosecution case in a nutshell is that on 20.10.2004, a function for establishment of Durga idol was held at the village

Procedural History: Trial Court convicted appellants under Sections 302, 307, and 504 of IPC -- High Court affirmed conviction of Anjani Singh and Ravindra Singh but acquitted Rishabh Dev Singh -- Supreme Court heard appeal after abatement of Ravindra Singh's appeal

Acts and Sections:
  • Indian Penal Code, 1860: Section 302, Section 307, Section 504, Section 34