Legal Review and Analysis of Kannaiya vs State of Madhya Pradesh 2025 INSC 1246
1. Heading of the Judgment
Case Title: Kannaiya vs. State of Madhya Pradesh
Citation: 2025 INSC 1246
Court: Supreme Court of India
Jurisdiction: Criminal Appellate Jurisdiction
Criminal Appeal No.: 116 of 2012
Judges: Hon'ble Mr. Justice Sandeep Mehta and Hon'ble Mr. Justice Sanjay Karol
Date of Judgment: October 17, 2025
2. Related Laws and Sections
The judgment primarily deals with the following legal provisions:
Indian Penal Code, 1860 (IPC):
Section 302: Punishment for Murder.
Section 34: Acts done by several persons in furtherance of common intention.Code of Criminal Procedure, 1973 (CrPC):
Section 374(2): Appeal from convictions by Sessions Judges.
Section 313: Power to examine the accused.Indian Evidence Act, 1872:
Section 27: How much of information received from accused may be proved.Constitution of India, 1950:
Article 142: Power of the Supreme Court to pass any decree or order necessary for doing complete justice in any cause or matter pending before it.
3. Basic Judgment Details
This criminal appeal was filed by the accused-appellant, Kannaiya, challenging the judgment of the Madhya Pradesh High Court which had upheld his conviction and life imprisonment sentence. The appellant, along with three others (Govardhan, Raja Ram, and Bhima), was convicted by the Trial Court for the murder of one Ramesh under Section 302 read with Section 34 of the IPC. The prosecution's case relied on the testimonies of two eyewitnesses, Madho Singh (PW-5) and Puniya (PW-12). The Supreme Court was tasked with re-appreciating the evidence to determine the sustainability of the conviction.
4. Core Principle and In-Depth Analysis of the Judgment
The core issue before the Supreme Court was whether the conviction of the appellant, based solely on the testimonies of two eyewitnesses which were riddled with irreconcilable contradictions and improbabilities, could be sustained in law.
A. The Paramount Importance of Reliable Eyewitness Testimony
The Supreme Court began its analysis by reiterating the foundational principles for evaluating witness credibility. It relied on the precedent set in Vadivelu Thevar v. State of Madras (AIR 1957 SC 614), which classifies witnesses into three categories:
Wholly reliable.
Wholly unreliable.
Neither wholly reliable nor wholly unreliable.
The Court emphasized that the law is concerned with the quality of evidence, not its quantity. A conviction can be based on the testimony of a single witness if it is found to be wholly reliable. Conversely, if a witness is found to be wholly unreliable, their testimony must be discarded entirely. For witnesses falling in the third category, the court must seek corroboration in material particulars before acting upon their testimony.
B. Deconstruction of Prosecution Evidence and Uncovering Fatal Flaws
The Court meticulously dissected the evidence of the two key eyewitnesses, Puniya (PW-12) and Madho Singh (PW-5), and found their testimonies to be fundamentally untrustworthy for several reasons:
Contradictions in the Genesis and Place of Occurrence:
The FIR stated the incident began when the accused were damaging the hut of Jagya (PW-3), and Ramesh intervened.
Puniya (PW-12) completely shifted the scene, claiming the assault occurred in the field of one "Gopya" and made no mention of any hut demolition.
Madho Singh (PW-5) gave a third version, alleging the accused gathered near the house of "Narsingh" and that Ramesh was casually sitting at his (PW-5's) house smoking a bidi when the assault began.
The Court held that this complete variance regarding the very start and location of the incident "demolishes the very substratum of the prosecution case."Mutual Omission of Presence:
Both eyewitnesses explicitly denied the presence of the other at the crime scene during the assault. Puniya (PW-12) stated he was the only one who reached the spot, while Madho Singh (PW-5) categorically stated that no one else was present. This created an irreconcilable conflict between the two star witnesses.Conduct Unbecoming of an Eyewitness:
The Court found the conduct of Puniya (PW-12) highly unnatural. He claimed to have seen his cousin brother Ramesh being brutally assaulted by four armed men, yet he did nothing to intervene, raise an alarm, or help the victim immediately. He alleged he ran away and only returned an hour later. The Court found this apathy created a "grave doubt regarding the witness’s presence at the crime scene."Omission in the FIR:
The FIR, lodged by the victim's father Gobariya (PW-2), did not mention Puniya (PW-12) as an eyewitness. The Court reasoned that in a small village where everyone is known, and given that Puniya was a relative and the incident allegedly started at his father's hut, this omission was "material" and impugned the bona fides of the prosecution story.Inherent Improbabilities:
The Court found it highly improbable that Madho Singh (PW-5) could have stood just two steps away while ten assailants, some armed with sharp weapons, indiscriminately assaulted Ramesh, and yet escaped entirely unscathed and without any attempt to harm him.
C. Legal Precedent on Doubtful Genesis
The Supreme Court fortified its reasoning by citing Pankaj v. State of Rajasthan (2016) 16 SCC 192, which holds that "when the genesis and the manner of the incident is doubtful, the accused cannot be convicted." It also referred to Bhagwan Sahai v. State of Rajasthan (AIR 2016 SC 2714), which states that once the prosecution is found to have suppressed the origin of the occurrence, the only proper course is to grant the benefit of doubt.
D. Final Outcome and Exercise of Power under Article 142
The Supreme Court concluded that the prosecution had failed to prove its case beyond a reasonable doubt. The testimonies of PW-5 and PW-12 were found to be so contradictory and unreliable that it would be unsafe to uphold the conviction.
The Court acquitted the appellant, Kannaiya.
In an extraordinary exercise of power under Article 142 of the Constitution to ensure complete justice, the Court also extended the benefit of acquittal to the three co-accused (Govardhan, Raja Ram, and Bhima) who had not filed appeals before the Supreme Court. They were ordered to be released from custody if not required in any other case.
5. Final Outcome
The Supreme Court allowed the appeal. The impugned judgments of the Trial Court and the High Court were set aside. All four convicted accused persons—Kannaiya, Govardhan, Raja Ram, and Bhima—were acquitted of all charges.
6. Multiple Choice Questions Based on the Judgment
1. In Kannaiya vs. State of MP (2025 INSC 1246), the Supreme Court primarily set aside the conviction because?
A. The deceased died due to natural causes.
B. The forensic evidence was inconclusive.
C. The eyewitness testimonies were wholly unreliable and contradictory.
D. The appellant had an alibi that was proven.
2. The Supreme Court, in its judgment, extended the benefit of acquittal to the non-appealing co-accused by invoking its powers under?
A. Section 482 of the Code of Criminal Procedure, 1973.
B. Section 374(2) of the Code of Criminal Procedure, 1973.
C. Article 142 of the Constitution of India.
D. Section 27 of the Indian Evidence Act, 1872.
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