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Supreme Court Says Circumstantial Chain Can Outweigh Missing Eyewitness In Murder Trial

The Supreme Court has reaffirmed that a murder conviction does not collapse merely because nobody directly witnessed the crime. If the surrounding facts form a consistent and credible chain pointing toward the accused, the prosecution case can still stand firm.

A Bench of Justice Aravind Kumar and Justice Prasanna B. Varale upheld the conviction of a man accused of murdering a tea stall owner in Ahmedabad, declining to disturb the concurrent findings recorded by the Trial Court and the High Court.

The case revolved around the killing of Somabhai Sankabhai Rabari, who operated a roadside tea stall. According to the prosecution, tensions erupted late on December 11, 1998, after the accused allegedly tossed a half-smoked cigarette into a bucket used for washing cups at the stall. The argument escalated, and threats were allegedly exchanged.

The following morning, the deceased’s brother rushed to the scene after learning Somabhai had been found grievously injured near the tea stall. Before being taken to hospital, the victim allegedly named the attacker and stated that he had been stabbed with a knife. The same allegation was repeated during the journey in an auto-rickshaw. He was declared dead on arrival at the hospital.

Investigators later claimed to have recovered the knife based on information supplied by the accused during the probe.

Before the Supreme Court, the defence argued that the conviction rested on shaky ground because no eyewitness had actually seen the stabbing take place. It was contended that the testimony of the complainant alone could not sustain a murder conviction.

The Court, however, found the argument unpersuasive.

The judges noted that while the complainant was not present during the assault, his testimony carried weight because the victim himself repeatedly identified the accused as the assailant immediately after the incident. That version, the Court said, was materially strengthened by the testimony of an auto-rickshaw driver who happened to pass by the area and supported the prosecution narrative.

The Bench observed that the absence of a direct eyewitness does not automatically weaken a criminal case when the attending circumstances clearly establish involvement of the accused.

The judgment also underscored a long-settled principle of criminal law — courts are concerned with the quality of evidence, not the number of witnesses produced. Even a single witness can be sufficient if the testimony is trustworthy and withstands scrutiny.

Referring to the auto-rickshaw driver’s evidence, the Court said his account remained consistent throughout cross-examination and contained no material contradictions capable of damaging his credibility. The testimony was described as natural, reliable and fully supportive of the prosecution story regarding the accused’s role in the killing.

With those findings, the Supreme Court dismissed the appeal and confirmed the murder conviction.

The ruling came in Mitesh @ T.V. Vaghela vs State of Gujarat.

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