Arjun and Rakesh were close friends and also colleagues who seemed to celebrate every aspect of their

life
together. One day some disagreement happened between them, which only became worse day by day, and their
families were worried about it too. On 12-02-2022 at 6:00pm Rakesh told his family that Arjun wanted to meet at a
nearby park and that he was going to meet Arjun. At 8:30pm Rakesh’s sister-in-law was returning from work and
saw that Arjun was yelling at Rakesh in a very loud voice and they suddenly started fighting. She was worried for
both of them and started to walk towards them. When she was close enough to see both of them clearly, she saw
Arjun picking a knife from a food stall beside them and before she could do anything Arjun stabbed Rakesh
multiple times with that knife. Rakesh fell on the ground and Arjun fled away. Rakesh was taken to the adjacent
clinic, where the doctors advised them to take him to Dr.Rao hospital which was the nearest hospital where
emergency treatment could be given. By the time they reached the hospital Rakesh was declared dead.
Post-mortem was conducted on the deceased the next day i.e. 13-02- 2022, wherein several injuries were
detected and two among them were found to be fatal. An FIR was registered on the date of the incident itself i.e.
12-02-2022 on the statement of the deceased’s sister-in-law, the complainant. The police started the investigation
and they received information that the accused was seen in a street near Hamilton road. When police went there
they found the accused coming out of a street holding the knife. The accused was arrested and the knife and the
clothes of the accused which were also stained by blood were recovered within a short period of time without any
gap and sent for forensic analysis. The police filed the chargesheet against the sole accused, u/sec-302 of the
penal code. At a trial before the Sessions court, 18 witnesses were examined by the prosecution. The Star witness
was the sister-in-law, who was the eye-witness. She was put to a lengthy cross-examination by the defence but
nothing came out to discredit her witness. The witness in her testimony narrates the entire sequence of events as
to how the deceased was stabbed to death. The forensic report showed that the blood found on the knife matched
with that of the deceased. The trial court found that the evidence is sufficient to prove that the accused committed
the murder and hence convicted the accused with life imprisonment. The High Court in the appeal before it upheld
the decision of the trial court. Aggrieved by the decision Arjun approached the Hon’ble Supreme Court in the
present criminal appeal stating that the prosecution did not establish the motive for the offence. Also, the manner
of recovery of the weapon and blood stained clothes suggest procedural irregularities and that the reliability on sole
eyewitness is insufficient to eliminate reasonable doubt.

Detailed Arguments for Both Sides

Issue 1: Does the lack of motive weaken the prosecution’s case?

Prosecution’s Arguments (Against Accused)

1.​ Motive is not a mandatory ingredient for conviction under Section 302 IPC if direct evidence
exists.
○​ Legal Principle: State of U.P. v. Kishanpal (2008) 16 SCC 73
■​ Supreme Court held: "When there is direct evidence of eyewitnesses, absence of
motive does not affect prosecution’s case."
○​ Legal Principle: Anwaruddin v. State of Telangana (2022) SCC Online SC 102
■​ "Motive is relevant but not indispensable when there is clear evidence of commission
of the offence."
2.​ Prosecution has established guilt beyond reasonable doubt through:
○​ Eyewitness testimony (sister-in-law’s account is consistent).
○​ Forensic evidence (blood on knife matches deceased).
○​ Recovery of weapon & bloodstained clothes (Sec. 27, Indian Evidence Act).
3.​ Motive is only a corroborative factor, not a substantive proof.
○​ Legal Principle: Gurcharan Singh v. State of Punjab (1956) SCR 827
■​ "Motive is in the mind of the accused and can rarely be proved with certainty."
Defense’s Arguments (For Accused, Arjun)

1.​ Motive is crucial when relying on circumstantial evidence.

○​ Legal Principle: Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116
■​ "In circumstantial evidence, absence of motive creates serious doubt."
2.​ No prior enmity or provocation was established.
○​ Legal Principle: Suraj Mal v. State (Delhi) (1979) 4 SCC 725
■​ "If motive is absent, the court must scrutinize evidence with greater caution."
3.​ Prosecution failed to explain sudden hostility, making the incident doubtful.

Issue 2: Can a single eyewitness’s statement be enough to convict under Section 302?

Prosecution’s Arguments

1.​ Law does not mandate multiple witnesses – Even one credible witness suffices.
○​ Legal Provision: Section 134, Indian Evidence Act
■​ "No particular number of witnesses shall be required for proof of any fact."
○​ Case Law: Vadivelu Thevar v. State of Madras (1957) SCR 981
■​ "The evidence of a single witness, if wholly reliable, is sufficient for conviction."
2.​ Sister-in-law’s testimony is:
○​ Clear & consistent (she saw the stabbing).
○​ Unshaken in cross-examination (defense failed to discredit her).
○​ Corroborated by forensic evidence (blood on knife).
3.​ Quality over quantity – Courts prefer trustworthy testimony over multiple unreliable witnesses.
○​ Case Law: Sunil Kumar v. State of Rajasthan (2005) 9 SCC 283

Defense’s Arguments

1.​ Relying on a sole eyewitness is risky – Human memory is fallible.

○​ Case Law: Kartik Malhar v. State of Bihar (1996) 1 SCC 614
■​ "Conviction based on a single witness requires strict scrutiny."
2.​ No independent witnesses (e.g., food stall owner, park visitors) were examined.
○​ Legal Principle: State of Punjab v. Jagir Singh (1973) 2 SCC 745
■​ *"Non-examination of independent witnesses weakens prosecution’s case."*
3.​ Possibility of exaggeration/bias – Sister-in-law is related to the deceased.

Issue 3: Is the forensic evidence linking the accused to the crime admissible?

Prosecution’s Arguments

1.​ Forensic evidence is scientifically reliable and supports eyewitness account.

○​ Legal Provision: Section 45, Indian Evidence Act
■​ "Expert opinion (blood match) is admissible."
○​ Case Law: State of Himachal Pradesh v. Raj Kumar (2018) 5 SCC 205
■​ "Forensic reports can corroborate eyewitness testimony."
 2.​ Recovery of knife & clothes was prompt (no tampering).
○​ Legal Provision: Section 27, Evidence Act
■​ "Confession leading to recovery is admissible."
3.​ Chain of custody was maintained – Forensic report confirms blood matches deceased.

Defense’s Arguments

1.​ Procedural lapses in recovery – Police did not follow proper documentation.
○​ Case Law: Pandurang v. State of Hyderabad (1955) SCR 1083
■​ "If recovery is doubtful, evidence becomes weak."
2.​ Chain of custody not proven – No proof that the same knife was used in the crime.
○​ Legal Principle: Mohan Lal v. State of Punjab (2018) 17 SCC 627
■​ "Prosecution must prove continuity of possession of evidence."
3.​ Possibility of contamination – Bloodstains could have been planted.

Final Prayers (Requests to Court)

Prosecution’s Prayer (Seeking Conviction)

●​ "In light of the unimpeachable testimony of the eyewitness, corroborated by forensic evidence and
recovery of the murder weapon, this Hon’ble Court may:
1.​ Uphold the conviction of the accused under Section 302 IPC.
2.​ Confirm the sentence of life imprisonment imposed by the trial court and affirmed by the
High Court.
3.​ Dismiss the present criminal appeal as devoid of merit."

Defense’s Prayer (Seeking Acquittal)

●​ "In light of the absence of motive, unreliability of a sole eyewitness, and procedural irregularities in
recovery of evidence, this Hon’ble Court may:
1.​ Set aside the conviction and sentence imposed by the courts below.
2.​ Acquit the accused of all charges under Section 302 IPC.
3.​ Grant the accused the benefit of doubt in the interest of justice."