The Supreme Court of India acquitted multiple accused persons in a brutal murder case, holding that the prosecution failed to establish guilt due to serious investigative lapses and unreliable evidence.
The bench of Justice Sanjay Kumar and Justice K. Vinod Chandran strongly criticised the manner in which the investigation was conducted, observing that a “scripted enquiry” can be more dangerous than an incompetent one, particularly when it risks implicating innocent persons.
The case arose from an incident in Assam where the deceased was allegedly attacked by a group of assailants using sharp weapons. According to the prosecution, the victim and others were travelling on motorcycles when they were ambushed on a road after a steel wire was stretched across it. The attackers then allegedly assaulted the victim brutally, causing multiple grievous injuries, including severing his hand. The post-mortem report confirmed that the death was homicidal and caused by severe injuries inflicted with sharp weapons.
Despite the gravity of the allegations, the Supreme Court found that the foundation of the prosecution case was deeply flawed. One of the most critical issues highlighted was the delay in registration of the FIR. Although the police had reached the scene promptly based on a General Diary entry, the FIR was registered only after two days on the basis of a written complaint by a person who was not an eyewitness. The Court observed that such delay, coupled with the naming of multiple accused in the complaint, raised serious doubts about deliberation and possible embellishment.
The Court also rejected the High Court’s approach of treating the General Diary entry as the FIR. It noted that neither the informant who provided the initial information nor the police officer who recorded it was examined during trial. In the absence of such evidence, the GD entry could not be legally treated as the first information report, thereby weakening the prosecution’s case at its very inception.
A major blow to the prosecution case came from the Court’s assessment of eyewitness testimony. While several witnesses claimed to have seen the incident, their statements were found to be inconsistent and lacking credibility. Most of these witnesses were close relatives of the deceased, and their presence at the scene was not convincingly established. Further, their statements were recorded belatedly, raising additional suspicion about their reliability. The Court held that mere repetition of the prosecution story by related witnesses, without corroboration, cannot form the basis of conviction.
The credibility of so-called injured eyewitnesses was also seriously undermined. Although the prosecution claimed that certain witnesses had sustained injuries during the incident, no medical records or wound certificates were produced to substantiate these claims. The Court observed that when injuries are not proved, the enhanced evidentiary value ordinarily attached to injured witnesses cannot be granted. This failure not only weakened their testimony but also cast doubt on their very presence at the scene of the crime.
Further, the investigation suffered from glaring procedural deficiencies. The Court noted that weapons allegedly used in the crime were neither properly examined nor sent for forensic analysis. Blood samples were not collected from the scene, and seized materials, including motorcycles, were not produced before the court during trial. Such lapses, according to the Court, severely undermined the integrity of the prosecution case and indicated a lack of due diligence in investigation.
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The Court also pointed out violations of procedural requirements under the Code of Criminal Procedure. Statements of key witnesses were not recorded promptly under Section 161, and those recorded under Section 164 were done much later, diminishing their evidentiary value. The failure of the investigating officer to act on available information immediately after reaching the scene further contributed to the collapse of the prosecution case.
Taking note of these cumulative deficiencies, the Supreme Court held that the prosecution had failed to prove its case beyond reasonable doubt. It emphasised that criminal convictions cannot be sustained on the basis of doubtful evidence or defective investigation. Consequently, the Court allowed the appeals, set aside the convictions, and acquitted the accused persons, while also cancelling their bail bonds.
In a broader observation, the Court urged the State authorities to ensure better training and supervision of investigating officers. It noted that failure to follow due procedure not only leads to acquittals but also results in wastage of judicial time and public resources, while leaving the actual crime unresolved.
This judgment reinforces the fundamental principles of criminal jurisprudence—that the burden lies on the prosecution to establish guilt through credible and legally admissible evidence, and that any serious lapse in investigation or procedure can vitiate the entire trial.
Case Details
Case Title: Sadek Ali @ Md. Sadek Ali and Anr. Versus The State of Assam and Anr.
Citation: JURISHOUR-979-SC-2026
Case No.: Criminal Appeal No.558 of 2021
Date: 28/04/2026
