The Supreme Court recently set aside a murder conviction, holding that a critical omission in the First Information Report (FIR) fatally undermined the prosecution’s case. The incident occurred in a village in Chhattisgarh, where the victim was attacked at night by two masked assailants. The FIR was registered by the victim’s father based on the account of the victim’s wife, who was the only eyewitness. Despite her awareness of the identity of one of the assailants, the FIR described the attackers only as “unknown masked men.” Subsequently, the wife identified one of the attackers — the appellant, her brother-in-law — by his voice and stated that his mask had slipped during the incident.
The Court emphasized that the omission to name a known accused in the FIR is not a trivial error but a serious defect that undermines the foundation of the prosecution. It observed that the eyewitness had detailed knowledge of the events, including the assailants’ arrival, how they entered the house, the way they subdued her husband, and the manner in which they carried him away. Given this detailed account, it was improbable that she would omit the identity of the attacker unless there were external influences or familial animosity motivating the delayed inclusion. The Court noted that the accused’s name appeared for the first time in the police statement recorded four days after the incident, raising serious doubts about the credibility and reliability of the identification.
The Bench held that the omission in the FIR struck at the core of the prosecution’s case. Since the FIR is a crucial document that captures the immediate account of the incident, it holds significant evidentiary value. Any material discrepancy or omission, particularly regarding the identity of the assailant, directly impacts the reliability of subsequent statements and testimony. The Court observed that introducing the accused’s name later in a manipulated narrative cannot serve as a substitute for the initial omission, and reliance on such belated statements would be unsafe for securing a conviction.
Given this fundamental lapse, the Supreme Court concluded that the evidence connecting the appellant to the murder was insufficient and unreliable. The failure to name the known accused in the FIR rendered the identification evidence weak, and no other credible evidence was available to establish the appellant’s guilt. Considering these factors, the Court allowed the appeal, set aside the conviction, and acquitted the appellant.
This judgment reaffirms the principle that when a witness is aware of the assailant’s identity, failure to mention the person in the FIR constitutes a material omission capable of dismantling the prosecution’s case. The Supreme Court emphasized that such omissions go to the root of the matter and that convictions cannot rest on belated or manipulated statements when the initial report fails to reflect the known identity of the accused. By focusing on the importance of accurate and complete reporting in the FIR, the Court underscored its role as a safeguard against wrongful convictions, particularly in cases of familial disputes or potential vendetta.
The ruling thus serves as a crucial precedent, highlighting the significance of immediate, precise, and truthful reporting in criminal investigations and reinforcing the evidentiary primacy of the FIR in criminal law.
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