CCTV Footage as Evidence - The primary evidence discussed in multiple sources is CCTV footage, which various witnesses and investigations have relied upon to establish the presence, movements, and actions of accused persons at the crime scene. Several reports highlight that CCTV footage was recovered from different locations, such as bus stands, hotels, and shops, and was used to identify suspects, their clothing, and their activities around the time of the incident ["2023 0 Supreme(Bom) 2237"] ["2025 Supreme(Online)(Bom) 4420"] ["2025 Supreme(Online)(Bom) 5308"] ["
MAHAMMAD ANWAR @ MUNNI MAHAMMAD IBRAHIM SHAIKH vs STATE OF GUJARAT - Gujarat
"] ["2023 Supreme(Online)(MP) 21640"] ["2025 Supreme(Online)(DEL) 145"].Limitations and Contradictions - Several sources point out limitations in the CCTV evidence. For example, witnesses like PW5 Shailesh, who runs a CCTV business, admitted during cross-examination that he is not an expert and that the availability and clarity of CCTV footage are questionable ["2023 0 Supreme(Bom) 2237"]. Some reports mention that CCTV footage was post-incident, not conclusively showing the accused at the time of the crime, or that footage was blurred, not clear, or not shown to witnesses for identification purposes ["2025 Supreme(Online)(Bom) 5308"] ["2025 Supreme(Online)(Del) 9558"].
Absence of Eye-Witness Support - Many sources emphasize that no eye-witness testimony directly links the accused to the act, and reliance on CCTV footage alone is contested. Some reports mention that witnesses who supported the case, such as PW2 Shaukat or PW4 Golu, did not see the actual incident or were not examined, and the FIR was sometimes based on police or informant reports rather than eyewitness accounts ["2023 Supreme(Online)(KAR) 3413"] ["2022 Supreme(Online)(All) 21650"] ["2022 0 Supreme(Del) 1998"].
Specific Incidents and Clothing - Several cases discuss the clothing of accused persons in CCTV footage versus what was recovered or claimed. For example, in some instances, the accused was seen in footage wearing a green shirt or a black floral shirt, which was contrasted with the bloodstained shirts recovered later. The footage was sometimes deemed insufficient to conclusively establish involvement, especially when it was post-incident or inconclusive ["
MAHAMMAD ANWAR @ MUNNI MAHAMMAD IBRAHIM SHAIKH vs STATE OF GUJARAT - Gujarat
"] ["2025 Supreme(Online)(Bom) 5308"].Judicial Findings - Courts have expressed skepticism about the sole reliance on CCTV footage, citing contradictions, poor quality, and lack of corroborative eyewitness evidence. Some judgments mention that CCTV footage, if not authenticated or clear, cannot be the sole basis for conviction, especially when eyewitness testimonies are absent or inconsistent ["2022 Supreme(Online)(DEL) 3790"] ["2025 0 Supreme(Cal) 442"] ["2022 Supreme(Online)(All) 21650"].
Analysis and Conclusion:While CCTV footage is a significant electronic form of evidence used to establish the presence and movements of accused persons, its limitations—such as poor quality, timing discrepancies, and post-incident recordings—are frequently highlighted. Several courts have noted that CCTV footage alone, especially when not corroborated by eyewitness testimony or when footage is inconclusive or blurred, cannot definitively prove the accused's involvement in the alleged crime. In the specific context of the query—Only CCTV Footage no Eye Witness for Second Accused Helping Loosen the Shirt where Weapon was Hide—the evidence suggests that CCTV footage was available but either did not conclusively show the accused helping or loosing the shirt or was not shown to witnesses for identification. The absence of eye-witness corroboration and the questionable clarity of footage imply that reliance solely on CCTV footage is insufficient to establish the accused’s role beyond doubt ["2023 0 Supreme(Bom) 2237"] ["2025 Supreme(Online)(Bom) 4420"] ["2025 Supreme(Online)(Bom) 5308"].
References:- ["2023 0 Supreme(Bom) 2237"]- ["2025 Supreme(Online)(Bom) 4420"]- ["2025 Supreme(Online)(Bom) 5308"]- ["
MAHAMMAD ANWAR @ MUNNI MAHAMMAD IBRAHIM SHAIKH vs STATE OF GUJARAT - Gujarat
"]- ["2023 Supreme(Online)(MP) 21640"]- ["2025 Supreme(Online)(DEL) 145"]- ["2023 Supreme(Online)(KAR) 3413"]- ["2022 Supreme(Online)(All) 21650"]- ["2022 0 Supreme(Del) 1998"]- ["2022 Supreme(Online)(DEL) 3790"]- ["2025 0 Supreme(Cal) 442"]