Supreme Court upholds murder conviction, relying on motive, dying declaration, and consistent witness testimonies despite hostile witnesses.

Case Name: Mitesh @ T.V. Vaghela v. The State of Gujarat

Citation: 2026 INSC 469

Date of Judgment/Order: 11 May 2026

Bench: Justice Aravind Kumar and Justice Prasanna B. Varale

Held: The Supreme Court upheld the conviction of the appellant for murder under Section 302 IPC, observing that the prosecution had successfully established the motive, mens rea, and actus reus through the testimonies of the complainant (PW-1) and an independent eyewitness (PW-12), corroborated by the dying declaration of the victim. Despite several witnesses turning hostile, including the complainant’s eyewitness account of the deceased’s identification of the appellant as the attacker, the Court found that the quality of evidence was sufficient to sustain the conviction. The Court reiterated that even a solitary, reliable eyewitness could support a conviction, dismissing the defense’s claim for benefit of doubt based on hostile witnesses.

Summary: The appellant, Mitesh @ T.V. Vaghela, was convicted for the murder of Somabhai Sankabhai Rabari, his neighbor, following a dispute over a cigarette. On 11 December 1998, the appellant allegedly assaulted the deceased with a sharp weapon, leading to fatal injuries. The deceased identified the appellant to his brother (PW-1) before succumbing to his injuries. Despite the testimonies of several key witnesses turning hostile, the High Court affirmed the Trial Court’s conviction, relying heavily on the consistent dying declarations made by the deceased and the corroborative testimonies of PW-12, an independent rickshaw driver who witnessed the attack. The Supreme Court upheld the conviction, agreeing with the High Court’s reasoning that the motive, intent, and act were sufficiently proven beyond reasonable doubt.

Decision: The Supreme Court dismissed the appeal, confirming the appellant’s conviction under Section 302 IPC for the murder of the deceased. The Court emphasized the reliability of the dying declaration and the corroborated evidence from independent witnesses. It rejected the appellant’s argument for benefit of doubt based on hostile witnesses, affirming that the conviction was substantiated by clear and credible evidence. The Court noted that the appellant had already served a substantial part of his sentence and granted him liberty to seek remission in accordance with applicable policies. Pending applications were disposed of.