In a recent Supreme Court judgment, the court upheld a conviction for a daylight murder based on direct ocular evidence. The case highlighted the significance of direct eyewitness testimony in establishing guilt beyond a reasonable doubt, even in the absence of a proven motive for the crime.

The judgment, delivered by a bench comprising Justices Sudhanshu Dhulia and PB Varale, sets a precedent emphasizing the weight of eyewitness testimony and forensic evidence in criminal proceedings.

The case involved an appellant charged under Section 302 of the Indian Penal Code for committing a daylight murder. The pivotal evidence in the case was the testimony of a sole eyewitness (PW-2), who provided a detailed account of how the accused committed the murder. The eyewitness's reliability was unquestioned, and the court placed significant weight on her testimony.

Additionally, forensic evidence played a crucial role in corroborating the eyewitness account. A blood-stained knife recovered from the accused matched the blood of the deceased, as confirmed by a forensic report. This physical evidence further supported the prosecution's case against the accused.

The Supreme Court's judgment emphasized the established principle in criminal jurisprudence that when direct ocular testimony inspires confidence and is corroborated by forensic evidence, the prosecution need not prove motive conclusively. While motive is generally an important consideration, especially in cases based on circumstantial evidence, its absence becomes inconsequential when direct eyewitness testimony is robust and trustworthy.

The court referred to previous legal precedents, such as the case of Shivaji Genu Mohite v. State of Maharashtra, which reiterated that the presence or absence of motive does not significantly impact the credibility of a reliable eyewitness account. In cases where there is direct evidence of the crime, such as in this case, motive becomes a secondary concern.

The quick succession of events, including the murder, the arrest of the accused, and the recovery of the murder weapon, further bolstered the prosecution's case. The seamless chain of events, coupled with the strong direct evidence, left little room for doubt regarding the accused's guilt.

Ultimately, the Supreme Court dismissed the appeal and directed the appellant/accused to surrender before the Trial Court to serve the remaining part of the sentence. This judgment reaffirms the importance of direct ocular evidence in criminal convictions, highlighting that a solid eyewitness account, supported by forensic evidence, can establish guilt even without a clear motive being established.

Case: CHANDAN vs. THE STATE (DELHI ADMN.),

CRIMINAL APPEAL NO.788 OF 2012.

Click to read/download judgment.