Legal Review and Analysis of Anjani Singh vs The State of Uttar Pradesh 2026 INSC 3

Case Synopsis

Case: Anjani Singh vs The State of Uttar Pradesh, 2026 INSC 3

Synopsis: The Supreme Court acquitted the appellant, emphasizing that a criminal conviction based solely on the inconsistent and uncorroborated testimony of a solitary witness, especially when contradicted by circumstances and other witnesses, is unsustainable. The prosecution failed to meet the standard of proof beyond reasonable doubt, entitling the accused to the benefit of the doubt.

1. Heading of the Judgment

Case Name: Anjani Singh vs The State of Uttar Pradesh
Citation: 2026 INSC 3
Court: Supreme Court of India
Judges: Justice Manoj Misra and Justice Joymalya Bagchi
Date: 5th January 2026

2. Related Laws and Sections

The judgment primarily deals with offenses under the Indian Penal Code, 1860 and the standard of proof required in criminal trials.

• Indian Penal Code, 1860:
  Section 302: Punishment for murder.
  Section 307: Attempt to murder.
  Section 504: Intentional insult with intent to provoke breach of the peace.
  Section 34: Acts done by several persons in furtherance of common intention.

• Core Legal Principle: The standard of "proof beyond reasonable doubt" and the reliability of a solitary eyewitness testimony in a criminal case.

3. Basic Judgment Details

Facts of the Case

• On 20.10.2004, during a cultural function in a village, an altercation occurred between the appellant, Anjani Singh, and the informant (PW-1) after Anjani allegedly beat PW-1's son.

• Later that night, Anjani, his brother Ravindra (since deceased), and their father Rishabh Dev Singh (acquitted by High Court) allegedly arrived armed. Ravindra (with a licensed rifle) and Anjani (with a country-made pistol) opened fire.

• The firing resulted in the deaths of two persons (Krishna Kant Verma and Banarasi) and caused gunshot injuries to five others, including PW-1.

• The First Information Report (FIR) was lodged promptly by PW-1. The police seized a broken rifle allegedly snatched from Ravindra.

• The Trial Court convicted all three accused. The High Court acquitted the father, Rishabh Dev Singh, but upheld the convictions of Anjani Singh and Ravindra Singh.

• In the Supreme Court, the appeal survived only for Anjani Singh, as Ravindra Singh had passed away.

Issues Before the Supreme Court

1. Whether the conviction of the appellant, Anjani Singh, based solely on the testimony of the injured informant (PW-1), could be sustained?

2. Whether the prosecution succeeded in proving its case against the appellant beyond all reasonable doubt, given the host of inconsistencies, hostile witnesses, and lack of corroborative evidence?

Ratio Decidendi (Court’s Reasoning)

• Unreliable Solitary Witness: The Court held that the testimony of PW-1, the sole eyewitness supporting the prosecution, was not reliable. His testimony was riddled with inconsistencies regarding the direction of firing, the specific role of the appellant, and the sequence of events.

• Hostile Witnesses & Contradictory Circumstances: Multiple other injured eyewitnesses, though declared hostile, consistently stated that the lights at the pandal went off during the firing, making identification impossible. This cast serious doubt on PW-1's claim of having clearly seen the assailants.

• Lack of Motive and Inherent Improbability: The alleged motive was against PW-1, yet he received only superficial injuries. Conversely, two individuals with no alleged motive were killed from close range. The Court found the prosecution's theory of targeted firing at PW-1 improbable.

• Tangible Evidence Not Corroborative: The seized rifle's magazine was not recovered at the scene; the magazine found at the spot did not match the seized rifle. The empty cartridge did not match the rifle's firing pin. This failed to conclusively connect the seized weapon to the crime.

• Benefit of Doubt: In light of the wavering testimony of the sole eyewitness, the lack of corroboration from other witnesses or physical evidence, and the improbabilities in the prosecution's version, the Court held that the prosecution had failed to prove its case beyond a reasonable doubt. The appellant was entitled to the benefit of the doubt.

4. Core Principle of the Judgment

Title: The Imperative of Corroboration and the Fallibility of a Solitary Witness

Main Issue

The core issue was whether a criminal conviction, particularly for grave offenses like murder, can be founded exclusively on the testimony of a single eyewitness when such testimony is inherently inconsistent, contradicted by other witnesses on material particulars, and unsupported by reliable corroborative evidence.

Supreme Court’s Analysis and Holding

The Supreme Court conducted a meticulous review of the evidentiary record. The Court underscored that while a conviction can legally be based on the testimony of a single witness, the testimony must be "of a sterling quality" — it must be clear, consistent, reliable, and inspire complete confidence.

In this case, the testimony of PW-1 failed this test for multiple reasons:

1. Internal Inconsistencies: PW-1 gave contradictory statements about the location of the assailants and the direction of fire.

2. Vague Allegations: His description of the specific role played by the appellant, Anjani Singh, was nebulous. He even stated that Anjani did not fire at the crowd when his brother's rifle was being snatched.

3. Contradiction by Circumstances: His claim of clear visibility was directly contradicted by all other injured witnesses who stated the lights had failed, a scenario the Court found probable, especially since one deceased was the generator operator.

4. Lack of Corroboration: His version was not corroborated by any other eyewitness or by conclusive forensic evidence linking the seized weapons to the crime.

5. Inherent Improbability: The prosecution's narrative of targeted violence against PW-1 was belied by the nature and distribution of injuries.

The judgment reaffirms the fundamental principle of criminal jurisprudence: "Proof beyond reasonable doubt" is not a mere formality but the bedrock of a just verdict. When the version of a solitary witness is clouded by doubt, contradicted, and seems improbable, it is unsafe to uphold a conviction. The Court's role is to ensure that no innocent person is convicted on shaky evidence, even if it results in the acquittal of the accused.

5. Final Outcome

The Supreme Court allowed the appeal. The conviction and sentence of the appellant, Anjani Singh, were set aside. He was acquitted of all charges. His bail bonds were discharged.

6. MCQ Questions Based on the Judgment

Question 1: In Anjani Singh vs State of Uttar Pradesh (2026 INSC 3), the Supreme Court acquitted the appellant primarily based on which fundamental legal principle?
A. The principle of locus standi
B. The principle of proof beyond reasonable doubt and the benefit of the doubt
C. The principle of double jeopardy
D. The principle of restitution

Question 2: The Supreme Court found the testimony of the sole eyewitness (PW-1) unreliable for all the following reasons, EXCEPT?
A. He had no criminal antecedents.
B. His testimony contained material inconsistencies regarding the location of firing.
C. His claim of proper lighting was contradicted by all other injured witnesses.
D. The specific role attributed to the appellant in the shooting was vague and unspecific.