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Supreme Court of India 2023-01-24 allowed

SHEO LAL vs THE STATE OF UTTAR PRADESH

Bench: 2 — Dipankar Datta, S. Ravindra Bhat

In Brief

Munna Lal and Sheo Lal were convicted by the trial court and upheld by the High Court for murdering Narayan in September 1985. The Supreme Court allowed their appeal and acquitted them, holding that the prosecution failed to prove guilt beyond reasonable doubt. Although medical evidence and two eyewitnesses (PW-2, the victim's son, and PW-3, a chance witness) testified to their guilt, the Court found that PW-2 harboured a 10-year-old enmity with the appellants over property disputes and could have falsely implicated them. PW-3's testimony was unreliable—his presence at the scene was unexplained, his statement was recorded 24 days late, and other named eyewitnesses were not examined. Key investigation gaps included non-seizure of weapons, non-examination of the Investigating Officer, and inconsistencies in the medical evidence regarding a recovered bullet. The Court held the appellants entitled to the benefit of doubt.

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Criminal Law Murder Eyewitness Evidence Criminal Procedure Witness Examination Investigation Enmity and Motive Benefit of Doubt

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