Legal Analysis: Adalat Yadav etc. vs. State of Bihar

Citation: 2026 INSC 403
Court: Supreme Court of India
Bench: Justice Sanjay Karol & Justice Nongmeikapam Kotiswar Singh 
Judgment Author: Justice Sanjay Karol
Date of Decision: April 22, 2026
Nature of Judgment: Criminal Appeal under Article 136 against High Court judgment affirming conviction and sentence for murder and other offences.

Synopsis of the Judgment

The appellants (father and son) were convicted under Sections 302, 307, 149, 120B IPC and Section 27 of the Arms Act for the murder of Ram Sharan Yadav. The trial court and High Court relied on the testimony of the complainant (PW‑5), who was an injured eyewitness. The High Court had doubted the credibility of four other eyewitnesses (PW‑1 to PW‑4) but convicted the appellants solely on the basis of PW‑5’s testimony. The Supreme Court dismissed the appeals, holding that the testimony of a single injured eyewitness, if of sterling quality and consistent with the prosecution case, is sufficient to sustain a conviction. The Court rejected arguments regarding delay in filing FIR, minor inconsistencies with medical evidence, lack of independent witnesses, and non-examination of certain police officials.

1. Basic Information of the Judgment

Field Details Case Title Adalat Yadav etc. vs. State of Bihar Criminal Appeal Nos. 1788-1789 of 2019 Bench Justice Sanjay Karol Date of Decision April 22, 2026 Citation 2026 INSC 403 Appeal From Judgment dated 04.02.2017 of Patna High Court in Criminal Appeal (DB) Nos. 110/2012 and 79/2012

2. Legal Framework

Laws Involved:

• Indian Penal Code, 1860 (IPC): Section 302 (murder), Section 307 (attempt to murder), Section 149 (unlawful assembly), Section 120B (criminal conspiracy).

• Arms Act, 1959: Section 27 (punishment for using arms in contravention of the Act).

• Code of Criminal Procedure, 1973 (CrPC): Section 313 (examination of accused).

• Indian Evidence Act, 1872: Section 134 (number of witnesses – no particular number required), principles of evaluation of eyewitness testimony.

Precedents Cited:

• Lallu Manjhi v. State of Jharkhand (2014) – Evidence to be weighed, not counted; classification of witnesses into wholly reliable, wholly unreliable, or partly reliable.

• Amar Singh v. State (NCT of Delhi) (2020) – Single witness testimony can be acted upon if wholly reliable.

• Vadivelu Thevar v. State of Madras (1957) – Corroboration required only for the third category of witnesses.

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