Sanjay Khanderao Wadane v. State of Maharashtra — Post-mortem findings versus eyewitness testimony — weight of medical opinion evidence

Part of the Forensic Docket on Legal Desire Forensics — a conviction confirmed through final appeal, kept here as a method-of-crime record.

The facts

The deceased was beaten to death by the appellants over a long-standing dispute, and was convicted under provisions including Sections 143, 147, 148 and 302 read with 149, and Section 326 read with 149 of the Penal Code.

On appeal, the defence argued that the eyewitness account was unreliable because it mentioned the deceased eating ‘Bhel’ shortly before the incident — a detail that did not appear in the post-mortem examination — suggesting the witness’s narration was an afterthought.

The Supreme Court rejected this argument, holding that evidence given by a medical witness is merely opinion evidence, and the absence of a peripheral detail like stomach contents in the post-mortem report does not by itself discredit an otherwise credible eyewitness account of the assault.

The conviction was accordingly affirmed.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: A caution against over-reading post-mortem silence on incidental details as a contradiction: medical opinion evidence has real but limited evidentiary weight, and should not be stretched to override credible direct testimony on a peripheral point.

Case details

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.