Baban Shankar Daphal & Ors. vs. The State of Maharashtra, 2015

• The appellants were convicted of murder based on the allegation that they attacked the deceased, who had a property dispute with them, leading to the victim’s death due to severe injuries.
• The Trial Court initially acquitted all the accused, concluding that the eyewitness testimonies were unreliable and pointing out discrepancies between the medical evidence and the witnesses' accounts. The key inconsistency was that the eyewitnesses claimed the victim had been struck multiple times on the head, but this detail was not reflected in the medical report.
• The High Court reversed the acquittal, finding that the trial court had placed undue weight on minor inconsistencies and had failed to appreciate the overall credibility of the eyewitnesses.
• Aggrieved by the High Court’s ruling, the appellants approached the Supreme Court for redressal.

1. Whether the testimonies of eyewitnesses, particularly close relatives of the victim, should be discarded solely due to their relationship with the deceased?
2. Whether minor discrepancies between eyewitness testimonies and medical evidence are sufficient to render the testimonies unreliable and lead to acquittal? 
3. The extent to which the consistency of eyewitness testimonies should be assessed when they conflict with the medical report?
4. The Court explored the legal distinction between an “interested” witness (who has a personal stake in the outcome) and a “related” witness (a close relative with no stake other than being a witness to the incident)?

The Supreme Court, affirming the decision of the High Court, held that:

• The Supreme Court upheld the High Court's judgment, affirming the conviction of the appellants for the murder of the deceased.
• The Court emphasized that the testimonies of close relatives (eyewitnesses) should not automatically be discredited. Being related to the victim does not make a witness “interested” or biased unless there is clear evidence of a personal stake, such as a desire for revenge or false implications due to personal enmity.
• The Court also observed that minor inconsistencies between the eyewitnesses' statements and the medical evidence should not automatically lead to the dismissal of the testimonies. If the core facts of the case are consistent and the testimonies inspire confidence, they can still be used to convict the accused.
• The Court ruled that the Trial Court’s acquittal was perverse, as it focused too heavily on minor discrepancies and ignored the overall credibility of the witnesses and the circumstantial evidence.

The judgement clarified the applicability of following provisions:

• This decision strengthens the position of eyewitnesses in criminal cases, particularly relatives of the victims, ensuring that their testimony is not automatically disqualified due to their relationship with the deceased.
• The Court's emphasis on minor contradictions not being enough to discredit entire testimonies clarifies how evidence should be approached in murder trials and similar cases.
• The judgment protects the rights of victims' families by ensuring that their testimonies are considered seriously, despite potential personal connections to the case.
• The Court ensured fair trial principles by emphasizing that evidence should be judged in its entirety and not on individual discrepancies.
• The ruling has a significant societal impact in ensuring that justice is not denied simply due to a witness’s familial ties to the victim. This could promote confidence in the justice system, especially for those who may fear their testimonies would be automatically disregarded due to their close relationship with the victim.
• It also sets a clear precedent on how courts should treat inconsistent evidence in criminal trials, ensuring that the truth-seeking process is not hindered by minor errors in testimony.