Supreme Court Upholds Double-Murder Convictions After Acquittal, Holds Stomach Contents Cannot Displace Credible Eyewitness Testimony

Case Name — Shekappa and Others v. State of Karnataka                                                                                 Date of Judgment — 3 November 2026
Citation — 2026 INSC 1189
Bench — Justice K. V. Viswanathan and Justice Arun Palli

Held. The Supreme Court held that the Karnataka High Court was justified in reversing the acquittal because the trial court’s rejection of the eyewitness accounts was unreasonable on the evidence. The victims’ wives were natural witnesses to the midnight attacks, and their relationship to the deceased did not, by itself, make them interested witnesses. The post-mortem injuries corroborated their accounts. In these circumstances, an inconclusive estimate based on stomach and intestinal contents could not displace credible eyewitness testimony about the timing of the attacks. The Court also reiterated that an inquest report under Section 174 CrPC, corresponding to Section 194 BNSS, need not record the names of eyewitnesses.

Summary. Mallappa and Gulappa were killed in successive axe attacks during the night September 2001. Their wives identified the assailants and described their respective roles. One of the women was injured during the attack. The trial court acquitted the accused, relying in part on discrepancies in the testimony, the omission of eyewitness names from the inquest report and a medical estimate suggesting a four-hour gap between the deaths. The High Court reversed the acquittal. The Supreme Court agreed that the discrepancies did not undermine the core account and that the circumstances adequately explained the time taken to lodge the FIR the following morning.

Decision. The Supreme Court dismissed the appeal and upheld the convictions, including the life sentences for murder under Section 302 read with Section 149 IPC.