Satyanarayan Yadav & Ors. v. State of Bihar, Criminal Appeal (DB) No. 45 of 2008, Patna High Court (Justices Sanjay Kumar Singh and Ansul), decided on 05.10.2026 | CNR No. BRHC010606112008
The Patna High Court has acquitted three brothers who were serving life sentences for a 2005 murder in Jamui, because the case rested only on the testimony of the victim’s brother, whose story changed in court and whose evidence did not match the medical findings.
A conviction can rest on the testimony of a single witness only if it is wholly reliable and has the ring of truth. A sole witness who is a relative and also has a motive of enmity, such as a land dispute, must be tested with great care, and if his account in court materially improves on his police statement (proved as a contradiction through the investigating officer), it cannot be relied on. When the medical evidence is irreconcilable with the ocular version, such as blunt force alleged but incised wounds found, the medical evidence will prevail. An FIR and inquest report that have not been proved at trial cannot be looked at for their contents, and serious investigation lapses, such as no site plan, no blood at the spot and no weapon seized, can weigh in favour of the accused.
Govind Yadav was killed on 14 May 2005 in a field in Gambhariya village, and his brother Prayag Yadav said that Satyanarayan, Gopal and Jhotaha Yadav attacked him with the blunt side of a Tangi (a farm tool) over an old land dispute. The Jamui Sessions Court convicted all three under Sections 302/34 IPC in 2007. Justices Sanjay Kumar Singh and Ansul set aside the conviction after twelve witnesses had been examined. Nine of them turned hostile and said they knew nothing of the incident. The court held that the FIR (fardbeyan) and the inquest report were never proved or exhibited at trial, so they could not be looked at for their contents. It added that the fardbeyan was recorded at 9:15 pm, after the inquest had already begun at 8 pm, so it could not be treated as the earliest spontaneous version. Prayag’s account in court differed from his FIR, since he now said that one brother used the blunt side of a Tangi and the other two used lathis, and the investigating officer denied that he had told the police this, so the court treated this as a proved improvement. The court said a sole witness can support a conviction only if “wholly reliable”, and that Prayag, who was the deceased’s brother and admitted a pending land dispute with the accused, had to be tested more carefully, and nothing independent supported him. The doctor found incised wounds on the forehead and cheek, not on the neck as alleged, and the court held that the blunt side of a Tangi cannot cause an incised wound, so the medical evidence had to prevail. The investigating officer found no blood at the spot, no site plan was made, and no weapon was seized or produced. The court gave the accused the benefit of doubt and acquitted them.