Legal Review and Analysis of Dadu @ Ankush & Anr vs State of Madhya Pradesh & Anr 2025 INSC 1395
Case Synopsis
Dadu @ Ankush & Anr. vs. State of Madhya Pradesh & Anr., 2025 INSC 1395.
Synopsis: The Supreme Court acquitted appellants due to material contradictions in witness testimonies, lack of corroborative evidence, and improper appreciation of hostile witness evidence, reaffirming the principle of proof beyond reasonable doubt in criminal trials.
Acquittal in Atrocities Case: Supreme Court Emphasizes Evidentiary Consistency and Hostile Witness Scrutiny.
1. Judgment Heading
Dadu @ Ankush & Anr. vs. State of Madhya Pradesh & Anr., Criminal Appeal No. ...... of 2025 (Arising out of SLP (Criminal) No. 10759/2024), Supreme Court of India, Decided on December 08, 2025.
Judges: Justice Dipankar Datta and Justice Augustine George Masih.
2. Related Laws and Sections
Indian Penal Code, 1860: Sections 323 (voluntarily causing hurt), 354 (assault or criminal force to woman with intent to outrage her modesty), 294 (obscene acts or songs), 34 (acts done by several persons in furtherance of common intention).
Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989: Section 3(1)(xi) (punishment for atrocities).
Code of Criminal Procedure, 1973: Section 374(2) (appeals from convictions), Section 313 (examination of accused).
3. Basic Judgment Details
Facts of the Case
The appellants, Dadu @ Ankush (A-1) and Ankit (A-2), were convicted by the Special Court under the SC/ST Act and IPC for offences including outraging modesty, voluntarily causing hurt, and atrocities against a Scheduled Caste victim.
The prosecution case stemmed from an FIR lodged by the victim (PW-1) alleging that on October 4, 2015, the appellants came to her house, assaulted her, pulled her dupatta, scratched her neck, and beat her brother (PW-2) when he intervened.
The High Court upheld the convictions, leading to the appeal before the Supreme Court.
Issues Before the Supreme Court
Whether the prosecution proved the guilt of the appellants beyond reasonable doubt.
Whether the discrepancies in witness testimonies and lack of corroborative evidence vitiated the convictions.
Whether the High Court erred in disregarding the evidence of a hostile witness (PW-4) and in recording findings without sufficient proof.
Ratio Decidendi (Court’s Reasoning)
The Supreme Court meticulously analyzed the evidence, noting material contradictions between the FIR, victim’s deposition, and witness testimonies.
The victim did not attribute any physical assault to A-1; her account of A-2 pulling her dupatta and assaulting PW-2 lacked consistency.
PW-2’s testimony was found unreliable as he claimed many locals witnessed the incident but none were examined, and his version of injuries conflicted with medical evidence (PW-5).
The medical report indicated simple injuries possibly caused by a fall or drag, not necessarily by assault with a weapon.
PW-4, though declared hostile, gave an alternate version of a scuffle at the Ganesh Puja pandal, which the High Court wrongly rejected entirely. The Supreme Court cited State of U.P. v. Ramesh Prasad Misra (1996) 10 SCC 360, holding that evidence of a hostile witness must be scrutinized and can be accepted if consistent with the prosecution or defence case.
The High Court’s finding that the offence was committed because the victim belonged to a Scheduled Caste was perverse, as no evidence supported this inference.
The defence successfully raised probable doubt that the incident might have arisen from a scuffle at the pandal, leading to false implications.
4. Core Principle of the Judgment
Title: Reliability of Witness Testimony and Standard of Proof in Criminal Cases
Main Issue Addressed
The Supreme Court addressed whether convictions based on inconsistent, uncorroborated witness testimonies and improper appreciation of hostile witness evidence can be sustained, especially when the prosecution fails to prove guilt beyond reasonable doubt.
Analysis and Explanation
The judgment reinforces fundamental principles of criminal jurisprudence:
Beyond Reasonable Doubt: The prosecution must establish every ingredient of the offence with credible, consistent evidence. Here, discrepancies in the FIR, victim’s court deposition, and PW-2’s testimony created reasonable doubt.
Hostile Witness Evidence: The Court reiterated that evidence of a hostile witness cannot be outright rejected. It must be evaluated, and portions consistent with the case can be relied upon. The High Court’s failure to do so was erroneous.
Corroboration and Medical Evidence: Injuries noted in the medical report (PW-5) did not align with the alleged assault weapon (wood), and simple injuries could have resulted from a fall. Absence of independent witnesses despite claims of public presence further weakened the prosecution case.
Motive and Caste-Based Atrocity: The Court emphasized that mere knowledge of the victim’s caste does not prove an offence under the SC/ST Act unless intentional humiliation or discrimination is established. The High Court’s finding of caste-based motivation was unsupported by evidence.
Final Outcome
The Supreme Court allowed the appeal, set aside the convictions and sentences of both appellants, and discharged them from bail bonds.
5. MCQs Based on the Judgment
1. In Dadu @ Ankush & Anr. vs. State of MP, what was the Supreme Court’s primary reason for setting aside the convictions?
A) The appellants were juveniles at the time of the offence.
B) The prosecution failed to prove guilt beyond reasonable doubt due to inconsistent evidence.
C) The offence was compounded by the victim.
D) The Special Court lacked jurisdiction.
2. According to the Supreme Court, how should the evidence of a hostile witness be treated?
A) It must be completely disregarded.
B) It can be accepted in part if consistent with the prosecution or defence case.
C) It automatically strengthens the prosecution case.
D) It requires no further scrutiny.