Case Name: TALARI NARESH V. STATE OF TELANGANA
Petition Number: SLP (CRL.) No. 13614 of 2025
Neutral Citation: 2026 INSC 486
Date of Judgment: 13.05.2026
Coram:  HON’BLE MR. JUSTICE PRASHANT KUMAR MISHRA & HON’BLE JUSTICE MR. NV ANJARIA.
Relevant Provisions: Section 302 of the Indian Penal Code, Section 323 of the Indian Penal Code, Section 3(2)(v) of The Scheduled Castes and The Scheduled Tribes (Prevention of Atrocities) Act, 1989 and Section 3(1)(x) of The Scheduled Castes and The Scheduled Tribes (Prevention of Atrocities) Act, 1989.

INTRODUCTION

The dispute in the present case centered around whether the conviction of the appellant for offences under the IPC and the SC/ST Act could be sustained when the prosecution case rested on contradictory and unreliable eyewitness testimony, hostile witnesses, uncorroborated allegations regarding motive, and doubtful medical evidence containing material discrepancies and inconsistencies. The Supreme Court found the prosecution evidence unreliable and insufficient to sustain conviction, particularly in light of inconsistencies in the postmortem records, failure to examine independent witnesses, and contradictions between prosecution witnesses. The Court further held that testimony of a hostile witness, if found credible and corroborated by surrounding circumstances, can also be relied upon to discredit the prosecution case and support acquittal.

FACTS
The appeal challenged the concurrent conviction and sentencing of the appellant by the Trial Court and the High Court for offences under the IPC and the SC/ST Act. The appellant had been sentenced to life imprisonment along with fines and additional concurrent sentences for lesser offences. The prosecution alleged that the incident arose from prior hostility after the deceased had briefly eloped with the appellant’s sister, following which a village settlement required the deceased to stay away from the village.

According to the prosecution, when the deceased later returned to attend a wedding, the appellant confronted him near his house, leading to a quarrel during which the appellant allegedly attacked the deceased with a stone. The deceased’s mother, informed by a companion of the deceased, rushed to intervene and was also injured and allegedly subjected to caste-based abuse. The injured deceased was taken to hospital but died while being shifted for further treatment.

The investigation led to charges under the IPC and SC/ST Act. The prosecution examined eleven witnesses, including the deceased’s mother, relatives, medical officers, police officials, and panch witnesses, while some eyewitnesses turned hostile. Medical and forensic evidence confirmed injuries and the presence of human blood on the recovered stone and clothing. The Trial Court relied principally on the testimony of the deceased’s mother, corroborative evidence of relatives, medical findings, and forensic reports to convict the appellant, and the High Court affirmed the conviction and sentence leading to the present appeal.

ISSUE
Whether the conviction of the appellant for offences under the IPC and the SC/ST Act could be sustained when the prosecution case rested on contradictory and unreliable eyewitness testimony, hostile witnesses, uncorroborated allegations regarding motive, and doubtful medical evidence containing material discrepancies and inconsistencies?

JUDGMENT AND ANALYSIS
The Supreme Court closely scrutinized the prosecution evidence and found substantial contradictions and inconsistencies that undermined the conviction. The prosecution case primarily depended on the testimonies of the deceased’s mother and another alleged eyewitness. However, the latter turned hostile and denied informing the mother about the incident, directly contradicting the prosecution narrative. He also disowned his prior police statement, stating that it had been falsely recorded. Other witnesses similarly failed to support the prosecution’s version regarding the alleged village meeting said to have provided the motive for the crime.

The Court further noted that the incident allegedly occurred on a busy public road near quarry operations with constant vehicular movement, yet no independent witness from the locality was examined. This omission significantly weakened the prosecution case. The medical evidence was also found unreliable due to unexplained discrepancies between the inquest report, postmortem report, and the doctor’s testimony regarding the timing of the autopsy and cause of death. The Court held that the evidentiary value of the medical evidence was substantially diminished.

Importantly, the Court emphasized the evidentiary value of hostile witnesses. It referred to settled precedents, including Khujji @ Surendra Tiwari v. State of Madhya Pradesh [(1991) 3 SCC 627] to observe that the testimony of a hostile witness is not wiped off the record and may be relied upon to the extent it is credible. The court furthered this principle and held that if hostile testimony can support conviction when corroborated, it can equally be used to discredit the prosecution and support acquittal where it inspires confidence. The Court applied this principle to the present case to conclude that the prosecution failed to prove the occurrence, motive, and guilt beyond reasonable doubt, and in the light of the same allowed the appeal and recorded the appellant’s acquittal.

CONCLUSION
The judgment reinforced the principle that criminal conviction must rest on reliable, consistent, and cogent evidence establishing guilt beyond reasonable doubt. The Supreme Court underscored that hostile witness testimony is not wholly effaced from the record and may be relied upon even to support acquittal where it appears credible and trustworthy.