Goverdhan vs. State of Chhattisgarh, Criminal Appeal No. 116 of 2011, Supreme Court of India, Judgment dated January 9, 2025, [2025 INSC 47].
- ByPravleen Kaur --
- 15 Jun 2025 --
- 0 Comments
The Supreme Court of India, in Goverdhan vs. State of Chhattisgarh [Criminal Appeal No. 116 of 2011, decided January 9, 2025; 2025 INSC 47], delivered a significant judgment clarifying the standard of proof required in criminal cases, particularly the meaning and application of “reasonable doubt” in the context of a murder trial under Section 302 read with Section 34 of the Indian Penal Code.
Facts and Background
The case involved the brutal murder of Suraj, committed by the appellants Goverdhan, Rajendra, and their father Chintaram, arising from a prolonged family conflict. While the Sessions Court and the High Court convicted Goverdhan and Rajendra for murder, acquitting their father, the appellants challenged these findings before the Supreme Court.
Legal Issues
The interpretation and application of the standard of “reasonable doubt” in criminal trials.
The reliability of eyewitness testimony, especially when witnesses turn hostile or have discrepancies in their statements.
Whether the evidence on record was sufficient to uphold the conviction beyond reasonable doubt.
Supreme Court’s Findings
The three-judge bench, comprising Justices B.R. Gavai, K.V. Viswanathan, and Nongmeikapam Kotiswar Singh, restated that “reasonable doubt” must be based on substantive and rational grounds, not on speculative, imaginary, or trivial apprehensions. The Court emphasized that the standard of proof in criminal law is “beyond reasonable doubt” and not “beyond all doubt.”
The Court meticulously examined the evidence, including the testimonies of eyewitnesses and complainants, noting discrepancies and inconsistencies. It held that the non-recovery of the weapon of crime is not fatal if there are direct and reliable witnesses. The testimony of police personnel involved in recovery need not be disbelieved merely because they are police witnesses.
The Court also clarified that hostile witnesses’ evidence cannot be entirely discarded if parts of their testimony support the prosecution. The judgment underscored that unless the findings of the lower courts are perverse or ignore material evidence, the Supreme Court should be slow to interfere with concurrent findings.
Conclusion
The Supreme Court partly allowed the appeal, reaffirming:
The principle that reasonable doubt must be fair, substantial, and grounded in reason and common sense.
The importance of evaluating the totality of evidence, including partially hostile witnesses and police testimony.
The need for judicial restraint in overturning concurrent findings unless perverse or ignoring evidence.
This ruling reinforces the high standard of proof required in criminal convictions and clarifies how courts should approach reasonable doubt in serious offenses like murder.
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