Criminal Law

Unreliable Witness Testimony Cannot Sustain Conviction

Case: Kannaiya vs. State of Madhya Pradesh Date: October 17, 2025 Citation: 2025 INSC 1246

⚠️ DISCLAIMER: This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

❓ Question

If an eyewitness's story has major contradictions about where and how a crime happened, can a person be convicted based on that testimony alone?

✅ Answer

No, a conviction cannot stand on such unreliable evidence. The Supreme Court has firmly ruled that when the core of the prosecution's case—the "genesis" of the incident and the "place of occurrence"—is riddled with irreconcilable contradictions and is not established with certainty, it creates a reasonable doubt. In such situations, the accused is entitled to the "benefit of doubt" and must be acquitted.

🧩 Understanding the Legal Principles

⚖️ What the Supreme Court Has Clarified

[1] The "Genesis" and "Place of Occurrence" Are the Foundation of a Case

The Court emphasized that the starting point of a criminal incident is its bedrock.

  • The Legal Reality: For a conviction to be safe, the prosecution must present a clear and consistent story about how the fight started and exactly where it happened.
  • Why This Matters: If this foundation is shaky or has multiple, conflicting versions, it casts doubt on the entire prosecution case.
  • The Application in this Case: The FIR said the fight started at a hut. One eyewitness said it started in a field, and another said it started near a different house. The Supreme Court found these were fundamental flaws that "demolish the very substratum of the prosecution case."

[2] Witnesses Are Judged by Quality, Not Quantity

The Court applied a classic legal principle for evaluating witness testimony.

  • The Guiding Principle: The law is concerned with the quality of evidence, not its quantity. A court can convict based on the testimony of a single, wholly reliable witness.
  • The Three Categories of Witnesses:
    1. Wholly Reliable: The court can convict based on their testimony alone.
    2. Wholly Unreliable: Their testimony must be rejected entirely.
    3. Partially Reliable: The court must be cautious and look for independent evidence to corroborate their testimony.
  • The Application in this Case: The Supreme Court categorized one key eyewitness as "wholly unreliable" due to major contradictions and unnatural conduct. The other key eyewitness was deemed only "partially reliable," and since there was no other evidence to support his story, his testimony could not form the basis for a conviction.

[3] The Conduct of Witnesses Must Be Natural

The Court scrutinized whether the witnesses acted as ordinary, reasonable people would in such a situation.

  • Assessing Human Behavior: The law expects that a witness's actions during and after a crime should be plausible.
  • The Application in this Case: One witness claimed to be the cousin of the victim and saw him being brutally attacked by a group. However, he did nothing to help, raise an alarm, or immediately assist the injured victim. The Court found this "rank apathy" to be unnatural and a strong reason to doubt his presence at the scene.

[4] The "Benefit of Doubt" is a Cornerstone of Justice

The Court reinforced that it is better to acquit a guilty person than to convict an innocent one.

  • The Legal Safeguard: The "benefit of doubt" is not a loophole but a fundamental right.
  • The Standard of Proof: In a criminal case, the burden is entirely on the prosecution to prove its case beyond reasonable doubt.
  • The Application in this Case: With the eyewitness testimony discredited and no other solid evidence, the prosecution failed to meet this high standard. The Supreme Court held that the accused were entitled to the benefit of doubt.

🧭 Your Action Plan

✅ If You Are a Witness to a Crime

1

Be Consistent and Truthful

Stick to the Facts: When giving your statement to the police and later in court, be clear, consistent, and truthful about what you saw. Do not add or omit key details.

Note Key Details: Try to remember and consistently report the core details: how the incident started, where it happened, who was involved, and what weapons were used, if any.

2

Your Conduct Matters

Act Reasonably: Your actions during and after the event will be examined. It is expected that you would try to help the victim or call for help, if it is safe to do so.

Explain Omissions: If your name is not in the initial FIR, or if you did not mention something important at first, be prepared to give a credible explanation for why that happened.

✅ If You Are Seeking Justice for a Crime

1

Ensure a Coherent First Information Report (FIR)

Review the FIR: The first version of events is crucial. Make sure the FIR accurately records the genesis, location, and sequence of events as you know them. Inconsistencies at this stage can weaken the case later.

2

Understand the Strength of Evidence

Quality Over Quantity: Know that one credible, consistent witness is more valuable than several contradictory ones.

Corroboration is Key: If a witness's story has some problems, look for other evidence—like medical reports, forensic evidence, or other witnesses—that can support the core of their account.

💡 Core Takeaway from the Supreme Court

"The edifice of a criminal conviction must be built on the solid rock of credible and consistent evidence. When the very foundation—the genesis and the place of occurrence—is fractured by irreconcilable contradictions, the entire structure becomes unsafe. In such a scenario, the law leans in favor of liberty, granting the benefit of doubt to protect the innocent from the horror of a wrongful conviction."

This judgment serves as a powerful reminder that the pursuit of justice requires unwavering adherence to due process and evidential standards. It protects every citizen from being convicted based on unreliable, contradictory, or fabricated evidence.

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