The Supreme Court has upheld the conviction and life imprisonment of a father-son duo in a murder case, emphasizing that quality of evidence outweighs quantity.
The bench of Justice Sanjay Karol and Justice N. Kotiswar Singh dismissed the appeals, affirming the conviction and reiterated the settled principle under Section 134 of the Evidence Act that no particular number of witnesses is required to prove a fact. What matters is the credibility and reliability of the testimony.
The bench held that a conviction can be sustained on the basis of a single eyewitness, provided the testimony is of “sterling quality”—consistent, trustworthy, and capable of withstanding cross-examination.
The case arose from a violent incident dated December 4, 2008, in Bihar’s Begusarai district, where the deceased, Ram Sharan Yadav, was shot dead in broad daylight. According to the prosecution, the accused persons, including Adalat Yadav and his son Anirudh Yadav, surrounded the deceased and opened fire, allegedly due to prior enmity and the deceased’s role as a witness in another criminal case.
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An FIR was lodged the same day, and following investigation, chargesheets were filed. The Trial Court convicted multiple accused under Sections 302, 307, 149, and 120B of the IPC, along with provisions of the Arms Act, sentencing them to life imprisonment. The Patna High Court subsequently upheld the conviction, primarily relying on the testimony of the injured complainant (PW-5), while discarding other eyewitnesses.
The appellants challenged the conviction on several grounds delay in FIR suggesting possible fabrication, inconsistency in place of occurrence, conflict between medical and ocular evidence, non-examination of key witnesses, and reliability of sole eyewitness (PW-5) after other eyewitnesses were disbelieved.
The Court emphasized that the testimony of an injured witness carries greater weight, as such a person is unlikely to falsely implicate others. In this case, PW-5 not only witnessed the incident but was also injured during the attack, lending strong credibility to his account.
Rejecting the argument of delay, the Court held that mere delay in lodging FIR is not fatal if satisfactorily explained. It noted that delay must be assessed in the context of surrounding circumstances and cannot automatically discredit the prosecution case.
On the alleged inconsistency between medical and ocular evidence, the Court held that both broadly indicated that the deceased was shot in the head. Such minor variations were held to be immaterial.
Further, it reiterated that ocular evidence generally prevails over medical opinion, especially when the eyewitness is reliable.
The Court acknowledged societal realities, observing that independent witnesses often hesitate to depose in violent criminal cases, particularly where influential or feared individuals are involved. Hence, non-examination of independent witnesses does not weaken the prosecution.
The Supreme Court concluded that the testimony of the injured eyewitness was credible, consistent, and sufficient to establish guilt beyond reasonable doubt. Accordingly, it upheld the conviction and sentences imposed by the lower courts and dismissed the appeals.
Case Details
Case Title: Adalat Yadav Etc. Versus The State Of Bihar
Citation: JURISHOUR-895-SC-2026
Case No.: CRIMINAL APPEAL NOS. 1788-1789 OF 2019
Date: 22/04/2026
