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Supreme Court of India 2025-12-08 allowed

GOVIND MANDAVI vs STATE OF CHATTISGARH

Bench: 2 — Vikram Nath, Sandeep Mehta

In Brief

On 17 April 2021, a man was murdered by masked assailants at a farm hut. His wife, the sole eyewitness, told her father-in-law that "two unknown masked persons" committed the crime. The FIR repeated this description without naming anyone. Four days later, the wife claimed that one attacker's mask had slipped, allowing her to identify the appellant (who was related to the family). Blood-stained articles were recovered and a Test Identification Parade was conducted. The trial court and High Court convicted the appellant. The Supreme Court acquitted him, holding that the omission of the accused's name from the FIR—despite the witness having provided detailed information—was fatal to the prosecution. The delayed identification, combined with prior family enmity and lack of conclusive forensic evidence, rendered the case unreliable and insufficient to prove guilt beyond reasonable doubt.

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Criminal Law Evidence Eyewitness Testimony First Information Report Identification Murder Criminal Procedure

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