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Lallu Manjhi & Anr. v. State of Jharkhand — Medical evidence, non-corroboration of sole eyewitness

Part of the Forensic Docket on Legal Desire Forensics — a case where forensic or identification evidence broke down on appeal.

The facts

The accused were convicted under Sections 147 and 302/149 of the Penal Code for murder, based substantially on the testimony of a sole eyewitness.

The Supreme Court found that this witness had improved his account during the trial compared to what he had originally stated, and that his testimony was not corroborated by the medical evidence on record.

The Court also identified infirmities in the investigation itself.

Beyond the evidentiary weaknesses, the Court noted a procedural defect: it is obligatory for the trial court to examine an accused so that he can personally explain the circumstances appearing against him, and in the absence of that opportunity, the prosecution’s evidence cannot safely be relied upon to convict.

Given the uncorroborated and improving testimony of the sole witness, the missing medical corroboration, and the procedural lapse, the Supreme Court held that the conviction was not justified and allowed the appeal.

Why this belongs in the Forensic Docket: An eyewitness account that keeps growing with each retelling needs medical evidence to anchor it — when the post-mortem findings don’t back up the story, and the accused was never given his own chance to explain, a conviction cannot stand on testimony alone.

Case details

Citation [2003] 1 S.C.R. 1
Case number Criminal Appeal No. 15/2002
Court Indian Supreme Court
Decided 2003-01-07
Module Failure Registry

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

Explore more in the Forensic Docket or browse the full Forensics hub.

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Anuj Kumar
https://legaldesire.com/about-us/
Legal Desire Media and Insights is a leading legal news and insights platform founded in 2012 by Anuj Kumar, a lawyer, author and legal industry entrepreneur with 14 years in legal publishing. Our editorial team covers judgments, deals, law firm updates, careers and policy across India, the US, UK and Gulf. Coverage is editorially independent; sponsored posts are labeled Partner Content. Contact: legaldesire.com/contact