Supreme Court Acquits Murder Convicts After Evidence Leaves Reasonable Doubt

Whether murder convictions could stand despite contradictions in eyewitness accounts and serious investigative omissions

A family brawl allegedly involved shooting. Five persons were tried; three were acquitted and two convicted under Section 302 read with Section 34 IPC and Section 27 Arms Act. The Patna High Court affirmed. The investigating officer prepared no site map and seized neither material from the scene nor bloodstained clothing.

Issue and applicable law

The central question was whether murder convictions could stand despite contradictions in eyewitness accounts and serious investigative omissions.

Applying Sharad Birdhichand Sarda, the Court held that an available innocent hypothesis prevents conviction. Related witnesses are not automatically interested, but testimony displaying a ring of falsity requires close scrutiny. Sections 302 and 34 IPC now broadly correspond to Sections 103 and 3(5) BNS.

Court's reasoning

The Court held that the prosecution circumstances did not point only to guilt and supported a reasonable hypothesis of innocence. Its principal reason was that the alleged transport of the body to a police station instead of a hospital was suspicious, weapons and scene evidence were absent, and related witnesses' testimony carried material contradictions.

Decision and practical effect

Both appellants were acquitted and given the benefit of doubt.

The ruling is significant because it clarifies how the stated legal standard should be applied to comparable disputes without extending the decision beyond the facts reported by the source.

Case details

• Case: Ashok Upadhyay and Another v. State of Bihar
• Court: Supreme Court of India
• Case number or citation: 2026 LiveLaw (SC) 917
• Judges: Justice J.B. Pardiwala and Justice Vinod K. Chandran
• Advocates: For appellants: Manan Kumar Mishra, Divya Roy, Anjul Dwivedi, Deveshi Mishra; for State: Manish Kumar, Divyansh Mishra and Kumar Saurav
• Source: https://www.livelaw.in/supreme-court/supreme-court-taking-dead-body-police-station-instead-hospital-suspicious-circumstance-549373