The Supreme Court acquitted the accused in a double murder case, ruling that the prosecution failed to prove guilt beyond reasonable doubt. The judgment emphasized that eyewitnesses must identify accused in court and link them to specific roles, noting material omissions and contradictions in testimonies. It reinforced Section 162 CrPC standards for reliable evidence, overturning concurrent convictions due to fatal investigative lapses.
Facts Of The Case:
The case involved a violent incident on March 24, 2001, in Masturi, Chhattisgarh, where nine accused armed with swords, lathis, and poleaxes allegedly attacked a medical shop, killing Manrakhan Singh and Narayan Singh and injuring five others, including family members of the deceased. The prosecution claimed the attack stemmed from a property dispute linked to a shop transferred due to an unpaid loan. Eyewitnesses, mostly relatives of the victims, implicated the accused, but their testimonies contained material omissions and failed to identify the accused in court during trial. The accused also filed a cross-complaint (Crime No. 49/2001), alleging injuries sustained during the clash, which was tried separately.
The Sessions Court convicted all nine under Sections 147, 148, 302/149, and 307/149 IPC, sentencing them to life imprisonment, upheld by the Chhattisgarh High Court in 2010. On appeal, the Supreme Court scrutinized witness accounts, noting critical lapses: delayed FIR (5.5 hours), unexplained injuries on accused, and failure to conduct Test Identification Parades. The Court acquitted all accused in 2025, holding that unreliable testimonies and procedural flaws rendered convictions unsustainable.
Procedural History:
The case originated with the FIR No. 50/2001 registered at Masturi Police Station on 24 March 2001 under Sections 147, 148, 302/149, and 307/149 IPC for the double murder and attempted murders. The Sessions Court, Bilaspur, convicted all nine accused in 2007, sentencing them to life imprisonment. The accused appealed to the Chhattisgarh High Court, which upheld the convictions in its 10 September 2010 judgment. The appellants then filed Criminal Appeal Nos. 1157/2011, 1608/2011, and 1713/2012 before the Supreme Court, which granted bail during pendency. After 14 years of litigation, the Supreme Court delivered its landmark judgment on 14 May 2025, acquitting all accused. The Court highlighted three critical procedural lapses: (1) failure to conduct Test Identification Parades, (2) non-joinder of cross-case (Crime No. 49/2001) despite overlapping facts, and (3) delayed recording of witness statements (up to 21 days post-incident). The Bench (Justices Oka, Mithal, and Amanullah) emphasized that these defects vitiated the trial, rendering the convictions legally unsustainable. The judgment reinforces Section 162 CrPC standards for witness reliability and the mandate for fair identification procedures in criminal trials.
Court Observation:
The Supreme Court made critical observations while overturning the convictions, emphasizing fundamental flaws in the prosecution’s case. It noted that eyewitnesses failed to identify the accused in court, a fatal omission undermining their credibility. The Court highlighted material contradictions between witness statements and police records, violating Section 162 CrPC. It criticized the 5.5-hour delay in FIR registration despite the police station being nearby, raising doubts about the prosecution’s version. The Bench underscored that the trial court ignored injuries on the accused, suggesting a possible cross-fight not investigated impartially.
It condemned the non-joinder of the cross-case (Crime No. 49/2001), depriving the court of a complete factual matrix. The judgment reiterated that mere presence in a mob isn’t sufficient for conviction under Section 149 IPC without proof of active participation. The Court also questioned the 21-day delay in recording witness statements, observing that memories fade over time, affecting reliability. These observations reinforced the presumption of innocence and the prosecution’s burden to prove guilt beyond reasonable doubt.
Final Decision & Judgement:
The Supreme Court delivered a decisive verdict on 14 May 2025, overturning the convictions in the Chhattisgarh double murder case and acquitting all eight accused. In a unanimous decision by Justices Oka, Mithal, and Amanullah, the Court held that the prosecution’s case suffered from fatal evidentiary gaps that rendered the convictions unsustainable under law.
The judgment made three landmark determinations:
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Witness testimony was unreliable due to:
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Failure to identify accused in court
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Material contradictions with police statements
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Unexplained 21-day delay in recording statements
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Procedural violations compromised fairness, including:
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Non-investigation of injuries on accused
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Non-joinder of cross-case (Crime No. 49/2001)
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Lack of Test Identification Parade
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Section 149 IPC liability not established as:
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No evidence showed common object to murder
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Mere presence in mob insufficient for conviction
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The Court quashed all sentences, canceled bail bonds, and reaffirmed that “benefit of doubt” is a fundamental right in criminal trials. This judgment sets a crucial precedent for evidentiary standards in group violence cases, emphasizing that procedural safeguards cannot be sacrificed for convictions.
Case Details:
Case Title: Tukesh Singh & Ors. vs. State of Chhattisgarh Citation: 2025 INSC 683 (Reportable) Appeal Number: Criminal Appeal No. 1157 of 2011 (with connected Appeals No. 1608/2011 & 1713/2012) Date of Judgment: May 14, 2025 Bench: Justice Abhay S. Oka & Justice Pankaj Mithal & Justice Ahsanuddin Amanullah
Download The Judgement Here