Supreme Court: Faulty Investigation Alone Cannot Lead to Acquittal in Criminal Cases

Last Updated on January 7, 2025 by Amit Patra

In a judgment that reinforces the efficacy of the criminal justice system, the Supreme Court has held that accused persons cannot claim acquittal solely on the ground of defective investigation, highlighting the duty of the court to appreciate the evidence as a whole.

The judgment has come in a case relating to violent clashes between members of the RSS and CPI(M) during a hartal, which claimed two lives. After the trial court convicted several accused under various IPC sections including murder, some were acquitted by the High Court while others’ convictions were upheld, leading to the present appeal.

Justices Sudhanshu Dhulia and Prasanna B. Varale, pronouncing the judgment, had said prosecution evidence must be evaluated independently of lapses in investigation which may be either by design or negligence. The Court said such defects can not be held to be automatically in favour of the accused if other reliable evidence is available.

The Court addressed a few fundamental legal principles in its judgment. In the interpretation of evidence, it applied the “noscitur a sociis” doctrine to interpret evidence in its proper context and explained the limitations of “falsus in uno, falsus in omnibus” (false in one thing, false in everything), saying that minor contradictions cannot be used to invalidate entire testimonies. The Court then relied on the Paras Yadav case to reinforce the principle that investigative lapses should not favor the accused.

Especially significant was the way the Court dealt with witness testimony. The Court, while recognizing minor discrepancies in statements, still considered the eyewitness accounts credible and fairly consistent as to the principal occurrences. The judgment pointed out that even “interested witnesses” can be credible if their testimony remains consistent and believable.

This decision has serious implications for the administration of criminal justice in India. It ensures that technical defects in investigation cannot override substantial evidence of guilt, while maintaining the responsibility of courts to due consideration of all available evidence. The judgment maintains proper balance between the protection of rights of accused persons and the defeat of justice because of imperfections in procedure.

For both practitioners and law enforcement, this decision spells out in crystal-clear terms what weight is given to investigative defects over other forms of evidence in criminal proceedings and cements the role of thorough case evaluation in the search for justice in criminal cases.