ORISSA HIGH COURT
S.K. Sahoo and Chittaranjan Dash, JJ.
Rankanidhi Nayak and Ors. – Appellants
versus
State of Orissa – Respondent
CRA No. 193 of 1997 and CRA No. 47 of 1998
Decided on 11.9.2025

IMPORTANT POINTS
(1) Murder and wrongful confinement – In every criminal trial, minor variations in detail are bound to occur – Discrepancies which do not go to root of prosecution case cannot obliterate otherwise trustworthy testimony.
(2) Human reactions to sudden and violent incidents differ from person to person – Law does not expect uniformity in conduct, nor does it require a witness to volunteer to police immediately after occurrence – Failure of a witness to come forward at the earliest opportunity does not, by itself, render his testimony abortive.
(3) Inquest Report – Evidentiary value – Object of inquest under Section 174 of Cr.P.C. is limited and circumscribed – While inquest report is a valuable document for recording factual aspects surrounding a death, it is not a substantive piece of evidence.
(4) Examination of accused – Section 313 Cr.P.C. embodies valuable safeguard to accused, ensuring that before being convicted, he is given opportunity to personally explain circumstances appearing against him in prosecution evidence – This provision is grounded in Principle of Natural Justice and aims to secure a fair trial.

Headnote:

(A) Explosive Substances Act, 1908 – Section 9(b) – Indian Penal Code, 1860 – Sections 341/302/34/[Sections 126/103(1)/3(5) – Bharatiya Nyaya Sanhita, 2023] – Murder and wrongful confinement – Common intention – Life imprisonment – In every criminal trial, minor variations in detail are bound to occur – Discrepancies which do not go to root of prosecution case cannot obliterate otherwise trustworthy testimony – What must be seen is whether evidence, taken as a whole, bears “ring of truth” and is consistent on material particulars – Inconsistencies pointed out by defence are too trivial and natural to dislodge core of prosecution case – Ocular version has substantial corroboration by medical evidence – Far from discrediting ocular account, medical evidence fortifies – Minor discrepancies or perceived contradictions highlighted by defence are inconsequential and do not erode substratum of prosecution case – Conviction and sentence partly affirmed. (Paras 25, 33, 38, 52, 53 and 54)

(B) Criminal Law – Appreciation of evidence – Doctrine of falsus in uno, falsus in omnibus has no application in Indian Criminal Jurisprudence – Our Courts have consistently held it to be a mere rule of caution, not a rule of law – Merely because a witness may have erred in regard to some aspect or exaggerated certain details, remainder of his evidence is not to be discarded if it is otherwise credible and trustworthy – Emphasis is on quality, not quantity, of evidence, and testimony of a witness may be accepted in part and rejected in part, depending on whether it inspires confidence – Only those inconsistencies which are capable of impeaching credit of a witness can be used as “contradictions” – Mere variations or omissions in earlier statements do not suffice to discredit a witness in entirety – Even if a part of testimony is found to be an exaggeration or inaccurate, Court is well within its right to rely on remainder, provided it inspires confidence and is corroborated by medical or other evidence – Human reactions to sudden and violent incidents differ from person to person – Law does not expect uniformity in conduct, nor does it require a witness to volunteer to police immediately after occurrence – Failure of a witness to come forward at the earliest opportunity does not, by itself, render his testimony abortive. (Paras 26, 27 and 29)

(C) Criminal Procedure Code, 1973 – Section 174 – Inquest Report – Evidentiary value – Object of inquest under Section 174 of Cr.P.C. is limited and circumscribed – While inquest report is a valuable document for recording factual aspects surrounding a death, it is not a substantive piece of evidence – Its evidentiary value lies in corroborating factum of death and apparent nature of injuries, and not in fixing liability upon individuals – In instant case, death of deceased was homicidal in nature, and that aspect stands conclusively proved through medical evidence as well as ocular testimony – Mere fact that names of accused persons do not appear in inquest report, does not by itself render prosecution version doubtful – Inquest serves as a preliminary step in investigation to understand “how” and “what” of a death, rather than “who” or “why” – Non-mention of names of accused persons in inquest report in no way undermines credibility of prosecution case. (Paras 43 and 44)

(D) Criminal Procedure Code, 1973 – Section 313 – Examination of accused – Section 313 Cr.P.C. embodies valuable safeguard to accused, ensuring that before being convicted, he is given opportunity to personally explain circumstances appearing against him in prosecution evidence – This provision is grounded in Principle of Natural Justice and aims to secure a fair trial – However, not every omission or imperfection in framing of questions under Section 313 will vitiate trial unless it is shown that prejudice has in fact been caused – Appellants cannot be heard to say that they were denied fair opportunity under Section 313 Cr.P.C. – Record demonstrates that incriminating circumstances were fairly put, their explanations were duly recorded, and their documents were admitted into evidence – Plea of prejudice is wholly unfounded. (Paras 46 and 48)

Result: Appeals dismissed.