Kannaiya vs State of Madhya Pradesh 2025 INSC 1246 - Partially Reliable Witness
Criminal Trial - When a witness falls within the category of a “partially reliable witness”, to act upon his testimony, the prosecution would be required to provide independent and credible corroborative evidence. (Para 55) [Context: SC sets aside concurrent conviction in murder case and observed: When the genesis and manner of the incident itself are doubtful, conviction cannot be sustained - The suppression of the genesis of occurrence and the shifting of the place of incident demolish the very substratum of the prosecution case. (Para 58-63)]
Case Info
- Case name: Kannaiya v. State of Madhya Pradesh.
- Neutral citation: 2025 INSC 1246.
- Coram: Justices Sanjay Karol and Sandeep Mehta.
- Judgment date: October 17, 2025.
Caselaws and Citations
- Vadivelu Thevar v. State of Madras, AIR 1957 SC 614.
- Pankaj v. State of Rajasthan, (2016) 16 SCC 192.
- Bhagwan Sahai and Another v. State of Rajasthan, AIR 2016 SC 2714.
Statutes/Laws Referred
- Indian Penal Code, 1860: Sections 302, 34, 147, 148, 149.
- Code of Criminal Procedure, 1973: Sections 374(2), 313.
- Indian Evidence Act, 1872: Section 27.
- Arms Act, 1959: Sections 25, 27.
- Constitution of India, 1950: Article 142.
#SupremeCourt sets aside conviction of all four accused in a 1990 Murder Case even though only one of them had filed appeal.
— CiteCase 🇮🇳 (@CiteCase) October 17, 2025
"When the genesis and manner of the incident itself are doubtful, conviction cannot be sustained”, the Court said. https://t.co/RXcHqAamFD pic.twitter.com/D98H2dFQTE
