Conviction Cannot Be Sustained on Contradictory Medical Evidence, Hostile Witnesses, and Unproved Motive in a Murder Trial
Case Name: Talari Naresh v. The State of Telangana
Citation: 2026 INSC 486
Date of Judgment/Order: 13 May 2026
Bench: Justice Prashant Kumar Mishra and Justice N.V. Anjaria
Held: The Supreme Court held that a conviction for murder cannot be sustained where the prosecution case is riddled with contradictions, hostile witnesses demolish the foundational narrative, the motive remains unproved, and the medical evidence itself becomes unreliable due to unexplained discrepancies. The Court held that though testimony of a hostile witness is admissible and may even support conviction if corroborated by reliable evidence, the same evidence can equally be relied upon to discredit the prosecution case and support acquittal where it destroys the prosecution’s version. The Court further held that postmortem reports are not substantive evidence by themselves and where the doctor conducting the autopsy fails to satisfactorily explain glaring inconsistencies in the medical record, the evidentiary value of such medical evidence stands substantially weakened.
Summary: The appellant was convicted under Sections 302 and 323 IPC and Sections 3(2)(v) and 3(1)(x) of the SC/ST (Prevention of Atrocities) Act for allegedly killing Shiva Shankar after a quarrel arising out of an earlier incident in which the deceased had eloped with the appellant’s sister. According to the prosecution, a village Panchayat had earlier resolved the dispute by directing the deceased to stay away from the village. The prosecution alleged that when the deceased later returned to attend a wedding, the appellant attacked him with a stone and also abused the deceased’s mother using casteist slurs. However, during trial, the prosecution’s eyewitness Narendar (PW-3) turned hostile and contradicted the prosecution’s story regarding informing the deceased’s mother and witnessing the incident. Other witnesses also denied that any Panchayat had been held regarding the alleged elopement. The Supreme Court found that the prosecution failed to examine any independent witness despite the alleged incident occurring on a busy public road with regular vehicular movement. The Court also noted serious inconsistencies in the postmortem records, including conflicting dates and timings relating to the autopsy and unexplained discrepancies regarding the time of death. The doctor conducting the postmortem failed to satisfactorily explain these contradictions. Relying upon precedents governing appreciation of evidence of hostile and interested witnesses, the Court held that the cumulative effect of the evidence completely discredited the prosecution story.
Decision: The Supreme Court allowed the appeal, set aside the judgment dated 04 February 2025 of the Telangana High Court as well as the conviction and sentence imposed by the Trial Court under the IPC and the SC/ST Act, 1989. The Court held that the prosecution had failed to prove the occurrence itself, the alleged motive arising out of the Panchayat proceedings, or the reliability of the medical evidence. The Court further held that both the Trial Court and the High Court committed a concurrent error in appreciating the evidence and sustaining conviction despite glaring inconsistencies and lack of credible corroboration. The appellant was acquitted of all charges and directed to be released forthwith unless required in any other case. Pending interlocutory applications stood disposed of.