The Supreme Court on April 22, 2026, dismissed criminal appeals filed by a father-son duo convicted in a 2008 murder case in Bihar. The Court upheld their life sentence, emphasizing that a conviction can rest on the testimony of a single, reliable eyewitness.
Background of the Case
The case arose from a 2008 shooting incident in Begusarai, Bihar. According to the prosecution, the complainant and his brother were returning home from court when they were surrounded by a group of armed individuals. The attackers allegedly opened fire, killing the complainant’s brother on the spot and injuring others.
The trial court convicted multiple accused, including the appellants, under charges of murder, attempt to murder, criminal conspiracy, and provisions of the Arms Act. The Patna High Court later upheld the conviction, primarily relying on the testimony of the injured complainant.
Before the Supreme Court, the appellants challenged the conviction on several grounds. They pointed to a delay in lodging the FIR, inconsistencies regarding the place of occurrence, and alleged contradictions between medical and eyewitness evidence. They also argued that key witnesses were not examined and that several eyewitnesses had been discredited by the High Court.
The State, however, defended the conviction, arguing that the injured eyewitness’s testimony was consistent, credible, and sufficient to establish guilt.
Court’s Observations
On Single Eyewitness Testimony
The bench clarified that conviction based on a single witness is legally permissible if the testimony is trustworthy.
“The evidence has to be weighed, not counted,” the Court observed, reiterating that quality of evidence matters more than quantity.
It found that the complainant, who was also injured in the incident, qualified as a reliable witness whose testimony carried significant evidentiary value.
On Delay in FIR
Addressing the delay in filing the FIR, the Court held that delay alone is not fatal to the prosecution’s case.
“Delay cannot be used as a ritualistic formula to discard the prosecution version,” the bench noted, adding that each case must be examined on its own facts.
The Court found no reason to doubt the prosecution’s explanation.
On Medical vs Eyewitness Evidence
The Court rejected the argument of contradiction between medical and eyewitness accounts. It held that both pointed to the same fact that the victim was shot in the head. Minor differences in description did not affect the core of the prosecution case.
It further emphasized that eyewitness testimony, especially from an injured witness, generally carries greater weight than medical opinion.
On Lack of Independent Witnesses
The bench also addressed the absence of independent witnesses. It noted that in cases involving violent incidents, reluctance of bystanders to testify is understandable.
“Hesitation on the part of common persons… is but natural,” the Court remarked.
Decision
After examining all contentions, the Supreme Court found no “manifest error” in the findings of the lower courts. It concluded that the prosecution had successfully proved its case beyond reasonable doubt.
The appeals were dismissed, and the convictions and sentences of the appellants were upheld.
Case Details:
Case Title: Adalat Yadav & Anr. vs State of Bihar
Case Number: Criminal Appeal Nos. 1788–1789 of 2019
Judges: Justice Sanjay Karol, Justice Nongmeikapam Kotiswar Singh
Decision Date: April 22, 2026
