Baban Shankar Daphal vs. State of Maharashtra
Citation: 2025 INSC 97; Criminal Appeal No. 1675 of 2015
Bench: Justice Vikram Nath, Justice Prasanna B. Varale
Background
This appeal arose from a conviction under Section 302 read with Section 34 of the Indian Penal Code (IPC) for murder, following a property dispute that escalated into a fatal attack. The Trial Court had acquitted Baban Shankar Daphal and co-accused, citing inconsistencies between eyewitness testimonies and medical evidence. The Bombay High Court, however, reversed the acquittal and convicted the accused, prompting the present appeal before the Supreme Court.
Key Issues
Whether the High Court erred in overturning the Trial Court’s acquittal based on minor inconsistencies in eyewitness accounts.
The evidentiary value of testimonies from witnesses related to the victim.
The standard for granting benefit of doubt in criminal trials.
Arguments
Appellants:
Contended that the High Court failed to appreciate significant contradictions between the medical and eyewitness evidence.
Argued that all eyewitnesses were relatives of the deceased, making their testimonies unreliable.
Emphasized that the Trial Court’s acquittal was based on sound reasoning, and overturning it would undermine established criminal jurisprudence.
Respondent (State):
Asserted that the High Court correctly gave primacy to the core consistency of eyewitness testimonies, despite minor contradictions.
Argued that the relationship of witnesses to the victim does not automatically render their evidence inadmissible or unreliable, citing established precedents.
Maintained that the overall evidence, including medical reports, corroborated the prosecution’s version and established guilt beyond reasonable doubt.
Supreme Court’s Analysis
The Court reaffirmed that the testimony of a related or interested witness cannot be discarded solely on the ground of relationship; what matters is the intrinsic reliability of the evidence.
Minor inconsistencies or contradictions in witness statements do not necessarily render the entire testimony unreliable, provided the core facts remain intact. Only material inconsistencies that create substantive doubt about the prosecution’s story can justify acquittal.
The Supreme Court emphasized that the role of the court is to discern the truth by considering the evidence as a whole, not by isolating minor discrepancies.
The benefit of the doubt must be based on rational and cogent grounds, not on conjectures or hypothetical inconsistencies, especially when the prosecution’s case is otherwise strong.
Decision
The Supreme Court upheld the High Court’s conviction, holding that the evidence, viewed in totality, clearly established the accused’s guilt beyond reasonable doubt. The Court clarified that related witness testimony, if credible, is sufficient for conviction, and minor inconsistencies do not vitiate the prosecution’s case.
Significance
This judgment reinforces the principle that the credibility of witness testimony is paramount, regardless of the witness’s relationship to the victim. It also clarifies that courts must focus on the substance of evidence rather than minor contradictions, ensuring that justice is not derailed by technicalities.
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