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SANJAY KAROL, N. KOTISWAR SINGH
Adalat Yadav – Appellant
Versus
State of Bihar – Respondent
Key Points: - The Court held that convictions may be based on the testimony of a single eyewitness if the testimony is of sterling quality and credible (!) (!) (!) (!) . - Delay in lodging the FIR cannot by itself defeat the prosecution; delay must be assessed in the context of explanations and total circumstances (!) (!) (!) . - Appellate review under Article 136 respects concurrent findings and does not require re-evaluation of every witness; the path chosen by lower courts should not be shown to have a manifest error (!) (!) .
JUDGMENT :
SANJAY KAROL J.
1. The appellant-convicts before us are the father and son, namely Adalat Yadav and Anirudh Yadav. Criminal Appeal No. 1788 of 2019 has been filed by Adalat Yadav, and Criminal Appeal No. 1789 of 2019 has been filed by Anirudh Yadav. Both challenging the common judgment dated 4th February 2017 passed in Criminal Appeal (DB)) No. 110 of 2012 and 79 of 2012 respectively, whereby the Division Bench, has confirmed finding of conviction and sentence awarded by the Additional Sessions Fast Track Court-IV Begusarai1 [‘Trial Court’] in terms of judgment dated 22.11.2011 passed in Sessions Trial No. 251 of 2019 sentencing them to undergo Rigorous Imprisonment for life under Section 302 and 149 read with Section 120B of Indian Penal Code, 18602 [‘IPC’] and also a fine of Rs.10,000/- and in default of payment of fine they shall undergo Simple Imprisonment for six months. The above convicts were further sentenced to undergo Rigorous Imprisonment for 10 years under Sections 307, 149 of the I.P.C. read with Section 120B of the I.P.C. with a fine of Rs.5000/- and in default of payment they shall undergo Simple Imprisonment for three months. Apart from this, they were also
No cases identified as bad law. None of the provided case law summaries contain keywords or phrases explicitly indicating they have been overruled, reversed, abrogated, or otherwise treated as bad law (e.g., no mentions of "overruled," "reversed," "abrogated," or equivalent negative treatments).
No cases can be confidently categorized into specific treatment patterns such as "Followed," "Distinguished," "Criticized," or "Questioned." The provided summaries describe legal principles and holdings from the cases themselves, without any explicit references to how subsequent decisions have treated these cases (e.g., no phrases like "followed in," "distinguished by," "criticized in," or similar indicators of judicial treatment).
All cases are uncertain due to lack of treatment indicators:
Rizwan Khan VS State of Chhattisgarh - 2020 5 Supreme 142: Summary states legal principles on police evidence and NDPS Act proof; no treatment keywords.
Ravasaheb @ Ravasahebgouda Etc. VS State Of Karnataka - 2023 3 Supreme 461: Discusses reliable witness testimony and minor discrepancies; no treatment indicators.
Ramdas VS State Of Maharashtra - 2006 8 Supreme 635: Addresses conviction based on prosecutrix testimony if truthful; no treatment indicators.
GANESAN VS STATE REPRESENTED BY ITS INSPECTOR OF POLICE - 2020 6 Supreme 592: Covers solitary prosecutrix evidence if trustworthy; no treatment indicators.
State Of H. P. VS Gian Chand - 2001 3 Supreme 588: Critiques High Court reversal of conviction due to delay/contradictions (uses "should not have prevailed"); implies reversal of lower court but no indication this case itself is treated negatively.
MANJIT SINGH VS STATE OF PUNJAB - 2019 7 Supreme 337: Lists principles on co-accused acquittal, alibi, etc.; phrase "opinion of the investigating agency has been overruled by judicial pronouncements" refers to prior judicial overruling of agency opinion, not treatment of this case.
Mohd. Naushad VS State (Govt. Of NCT of Delhi) - 2023 8 Supreme 406: Outlines sentencing primacy, presumption of innocence, etc.; no treatment indicators.
Ravinder Kumar VS State Of Punjab - 2001 6 Supreme 549: States delay in FIR not fatal if explained; no treatment indicators.
Rai Sandeep @ Deepu VS State of NCT of Delhi - 2012 5 Supreme 402: Notes conviction cannot be based on unreliable prosecutrix; no treatment indicators.
Goverdhan VS State Of Chhattisgarh - 2025 1 Supreme 65: Covers proof standards, FIR as evidence, interested vs. related witnesses; no treatment indicators.
Naresh @ Nehru VS State Of Haryana - 2023 0 Supreme(SC) 1026: Requires sterling eye-witness evidence for murder; no treatment indicators.
Lallu Manjhi VS State Of Jharkhand - 2003 1 Supreme 146: Results in acquittal by Apex Court due to case improvement and unreliable evidence; no indication of this Supreme Court decision being negatively treated subsequently.
(1) Supreme Court need not delve into each and every individual’s testimonies and instead only examine whether path adopted by Courts below is compromised by any manifest error.(2) Convictions on the....
Convictions based on inconsistent witness testimony and insufficient evidence cannot stand; reliance on child witnesses requires careful scrutiny and corroboration.
Conviction for murder by unlawful assembly sustainable on reliable sole eyewitness to killing, corroborated by medical evidence and abduction witnesses, despite FIR delay, witness non-examination, an....
The conviction based on the testimony of a sole injured eyewitness is valid if the testimony is credible and minor discrepancies do not overshadow the overall evidence supporting the charges of murde....
Conviction based on unreliable eyewitness testimony due to delays and contradictions cannot be sustained, emphasizing the need for credible evidence in criminal cases.
Conviction can be based on a sole eyewitness if credible, but significant inconsistencies and lack of corroborative evidence can lead to acquittal.
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