Facts Of The Case:
The case stems from an incident on 28th September 1990, where an altercation allegedly occurred in a village involving ten accused persons. According to the FIR lodged by Gobariya (PW-2), the incident began when the accused were damaging a temporary hutment belonging to Jagya (PW-3). Gobariya’s son, Ramesh, intervened to pacify them, upon which the assailants allegedly turned on him and assaulted him with weapons including a sword, axe, and sticks. Ramesh sustained severe injuries and succumbed to them on 5th October 1990. The police registered an FIR and, after investigation, charged all ten accused. The trial court convicted four accused, including the appellant Kannaiya, under Section 302/34 IPC, while acquitting six others. The High Court upheld the conviction. In appeal, the Supreme Court scrutinized the evidence, primarily of two eyewitnesses—Madho Singh (PW-5) and Puniya (PW-12)—finding grave contradictions between their testimonies and the FIR regarding the genesis of the fight and its exact location, which created reasonable doubt about the prosecution’s version of events.
Procedural History:
The procedural history of this case began with the conviction of the accused-appellant and three others by the First Additional Sessions Judge, Mhow, in 1999 under Section 302/34 IPC. Their appeal to the High Court of Madhya Pradesh was dismissed in 2009. Subsequently, the appellant, Kannaiya, filed a criminal appeal by special leave to the Supreme Court of India in 2012 (Criminal Appeal No. 116 of 2012). The Supreme Court, after hearing the appeal, allowed it in 2025. The Court set aside the concurrent convictions, acquitted all four convicts, and extended the benefit of its judgment to the three non-appealing co-accused in exercise of its powers under Article 142 of the Constitution.
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Court Observation:
The Supreme Court made critical observations on the reliability of the prosecution’s evidence. It found the testimonies of the two key eyewitnesses, Madho Singh (PW-5) and Puniya (PW-12), to be wholly unreliable and replete with material contradictions regarding the genesis of the incident and the precise location of the crime, which was at odds with the FIR and the site plan. The Court noted the witnesses suppressed the origin of the occurrence and denied each other’s presence at the scene. Furthermore, it observed the prosecution failed to provide any independent corroboration for this contradictory evidence. Citing precedents, the Court held that when the very foundation and manner of the incident are doubtful and the evidence lacks credibility, the accused are entitled to the benefit of doubt.
Final Decision & Judgement:
The Supreme Court allowed the appeal and set aside the impugned judgments of the courts below. It acquitted the appellant, Kannaiya, and extended the benefit of this judgment, in exercise of its powers under Article 142 of the Constitution of India, to his three co-convicts—Govardhan, Raja Ram, and Bhima—who had not filed appeals. The Court directed their release from custody forthwith, unless required in any other case, holding that the prosecution had failed to prove its case beyond reasonable doubt and the accused were entitled to the benefit of doubt.
Case Details:
Case Title: Kannaiya vs State of Madhya Pradesh Citation: 2025 INSC 1246. Criminal Appeal No.: Criminal Appeal No. 116 of 2012 Date of Judgement: October 17, 2025 Judges/Justice Name: Justice Sandeep Mehta and Justice Sanjay Karol.