Criminal Appeal Challenging a Conviction for Murder under Section 302 of the Indian Penal Code
- Reha Bhargav
- 17 October, 2025
Introduction
The case Ram Manohar Singh v. State of Uttar Pradesh, decided by the Supreme Court of India on August 24, 2023, concerns a criminal appeal filed by the appellant against his conviction under Section 302 of the Indian Penal Code (IPC) for murder. The appellant claimed that the prosecution’s case was unreliable, based on interested eyewitnesses, and lacked corroborative evidence. The appeal raised critical questions about the credibility of related witnesses, the principle of proof beyond reasonable doubt, and the extent to which the Supreme Court can interfere with concurrent findings of lower courts in criminal trials.
Background
The appellant, Ram Manohar Singh, was convicted by the trial court for the murder of a man with whom he had longstanding enmity. The incident reportedly occurred in broad daylight and was witnessed by several family members of the deceased. The trial court accepted these testimonies as reliable and convicted the appellant under Section 302 IPC, sentencing him to life imprisonment.
The Allahabad High Court upheld this conviction, agreeing that the eyewitnesses’ statements were consistent and trustworthy. Dissatisfied, the appellant moved the Supreme Court, alleging bias, false implication due to enmity, and lack of independent corroboration.
Key Developments
The trial court convicted the appellant under Section 302 IPC based on direct eyewitness accounts.
The Allahabad High Court upheld the conviction, finding no contradictions in the testimonies.
The appellant challenged both decisions before the Supreme Court, arguing that the witnesses were related and therefore biased.
The State of Uttar Pradesh defended the conviction, stating that related witnesses are not automatically unreliable if their evidence is credible.
The Supreme Court analyzed whether the lower courts had properly evaluated the evidence and whether the conviction could stand solely on the basis of such testimony.
Issues
Whether the conviction of the appellant under Section 302 IPC was justified based on the prosecution’s evidence.
Whether the testimonies of related eyewitnesses could be considered reliable and sufficient to sustain a conviction.
Whether prior enmity between the accused and the deceased created reasonable doubt about false implication.
Whether the Supreme Court should interfere with concurrent factual findings of the trial and High Court.
Current Status (Judgment)
The Supreme Court, comprising Justice Abhay S. Oka and Justice Sanjiv Khanna, dismissed the appeal and upheld the conviction. The Court held that the evidence of related witnesses, if consistent and trustworthy, cannot be rejected merely due to relationship with the deceased. It observed that the prosecution had proved guilt beyond reasonable doubt and that motive and direct evidence corroborated each other. The Court found no procedural or factual errors in the findings of the lower courts and confirmed the life imprisonment sentence.
Conclusion
The Supreme Court reaffirmed that credible and consistent eyewitness testimony, even from related witnesses, can validly form the basis for conviction in murder cases. The Court found no reason to doubt the veracity of the prosecution’s evidence and rejected the defense’s claim of false implication. The judgment upholds the principle that justice must be based on evidence quality rather than witness relationships, reinforcing the reliability of trustworthy testimony in criminal law.
