Rajesh Yadav v. State of UP
“Related Witnesses Are Not Interested Witnesses - Quality Over Quantity of Evidence”
TL;DR
The Supreme Court laid down important principles on witness examination in criminal trials. A related witness is not automatically an interested witness - the witness becomes interested only if there is evidence of motive to falsely implicate the accused. The Court also emphasized that evidence must be weighed, not counted - a single credible witness is sufficient for conviction.
The Bottom Line
Just because a witness is related to the victim does not make their testimony unreliable. Courts should focus on quality of evidence, not quantity. A single credible witness can lead to conviction.
Case Timeline
The journey from FIR to Supreme Court verdict
Incident
Two persons killed in election-related violence
Incident
Two persons killed in election-related violence
FIR Lodged
FIR registered within an hour of the incident
FIR Lodged
FIR registered within an hour of the incident
High Court Judgment
Convictions under Section 302 upheld, Section 307 set aside
High Court Judgment
Convictions under Section 302 upheld, Section 307 set aside
Supreme Court Judgment
Appeals dismissed, conviction upheld
Supreme Court Judgment
Appeals dismissed, conviction upheld
The Story
On September 17, 2004, two persons were killed in a violent attack arising from an election-related dispute between two factions. Multiple bullet injuries caused the deaths. An FIR was lodged within an hour by PW-1, who was the nephew of one deceased.
The trial court convicted the accused. The High Court upheld the convictions for murder (Section 302 IPC) and under Arms Act, but set aside convictions under Section 307 IPC (attempt to murder).
The appellants challenged before the Supreme Court arguing that the witnesses were relatives of the deceased and therefore interested witnesses whose testimony should be viewed with suspicion.
The Supreme Court examined the principles governing examination of witnesses, the distinction between related and interested witnesses, and the evidentiary value when witnesses turn hostile.
Legal Issues
Click each question to reveal the Supreme Court's answer
Arguments
The battle of arguments before the Supreme Court
Petitioner
Vihaan Kumar
Witnesses are relatives
The key witnesses are relatives of the deceased and therefore interested in securing conviction.
Hostile witnesses
Several witnesses turned hostile, casting doubt on the prosecution case.
Investigating Officer not examined
The investigating officer did not depose properly before the court.
Respondent
State of Haryana
Related not interested
Being related does not make a witness interested. There is no evidence of false implication motive.
Eyewitness testimony credible
The eyewitnesses gave consistent testimony that was not shaken in cross-examination.
Prompt FIR
FIR was lodged within an hour, ruling out fabrication.
Court's Analysis
How the Court reasoned its decision
The Supreme Court upheld the conviction, rejecting the argument that testimony of related witnesses should be viewed with suspicion. The Court emphasized that natural witnesses (those present at the scene) are often related to the victims, and disbelieving them solely because of relationship would defeat justice in most cases.
A related witness cannot be considered as an interested witness. A related witness would become an interested witness only when he is desirous of implicating the accused in rendering a conviction, on purpose.
Clarifies the distinction between related and interested witnesses.
Evidence has to be weighed and not counted. A single credible witness could suffice for conviction.
Quality over quantity principle for evidence.
Under Section 173(2) of CrPC, the final report forms a mere opinion of the investigating officer on the evidence pieced together by him. The truth of such a report can only be decided by the court.
Limits the evidentiary value of investigation report.
Trial courts shall endeavor to complete the examination of private witnesses both chief and cross on the same day as far as possible.
Procedural direction to prevent witness tampering.
The Verdict
Relief Granted
The conviction was upheld. The Court confirmed the High Court judgment.
Directions Issued
- Related witnesses should not automatically be treated as interested witnesses
- Trial courts should complete witness examination on same day where possible
- Private witnesses should be examined before official witnesses
- Evidence should be weighed, not counted
Key Legal Principles Established
A related witness is not automatically an interested witness.
A witness becomes "interested" only when there is evidence of motive to falsely implicate.
Evidence must be weighed, not counted - quality over quantity.
A single credible witness is sufficient for conviction.
Even hostile witnesses' prior statements can be relied upon.
Trial courts should complete witness examination on the same day.
Private witnesses should be examined before official witnesses.
Investigation report under Section 173(2) CrPC is mere opinion, not evidence.
Key Takeaways
What different people should know from this case
- If you witness a crime involving your relatives, your testimony is still valid and important.
- Being related to the victim does not disqualify you as a witness.
- Courts will evaluate whether your testimony is truthful, not just whether you are related.
- One truthful witness can be enough to convict the guilty.
Legal Framework
Applicable laws and provisions
Statutory Provisions
Section 134
Indian Evidence Act, 1872
“No particular number of witnesses shall in any case be required for the proof of any fact.”
Relevance: Statutory basis for single witness being sufficient for conviction.
Section 173(2)
Code of Criminal Procedure, 1973
“The officer in charge of the police station shall forward to a Magistrate empowered to take cognizance of the offence on a police report, a report...”
Relevance: The final report is mere opinion, not evidence itself.
Related Cases & Precedents
Dalip Singh v. State of Punjab
citedAIR 1953 SC 364
Laid down principles for evaluating testimony of related witnesses.
State of Rajasthan v. Smt. Kalki
cited(1981) 2 SCC 752
Held that related witnesses are natural witnesses and their testimony should not be discarded.
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