Edakkandi Dineshan @ P. Dineshan & Ors. Vs. State of Kerela [Criminal Appeal No. 118 of 2013]
- ByPravleen Kaur --
- 15 Jun 2025 --
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The Supreme Court of India, in Edakkandi Dineshan @ P. Dineshan & Ors. vs. State of Kerala [Criminal Appeal No. 118 of 2013], delivered its judgment on January 6, 2025, affirming the conviction of several accused persons for murder and related offences while acquitting others, and clarifying principles related to witness credibility and investigation quality.
Facts and Background
The case arose from violent clashes between members of the Rashtriya Swayamsevak Sangh (RSS) and the Communist Party of India (Marxist) during a hartal in Kerala, which resulted in the deaths of two individuals. Multiple accused were charged under Sections 302 (murder) read with 149 IPC, and some under the Explosive Substances Act, 1908.
The trial court convicted several accused and acquitted others. The Kerala High Court confirmed convictions for some accused while acquitting others. The appellants challenged their convictions before the Supreme Court.
Legal Issues
The reliability of eyewitness testimony despite minor contradictions and the principle of “falsus in uno, falsus in omnibus.”
Whether faulty or defective police investigation can be a ground for acquittal.
The adequacy of evidence to sustain convictions under Sections 302 IPC and Section 5 of the Explosive Substances Act.
Supreme Court’s Analysis and Findings
The Supreme Court held that minor discrepancies in witness testimonies are natural and do not necessarily discredit the entire prosecution case. It emphasized that the principle “falsus in uno, falsus in omnibus” (false in one thing, false in everything) does not apply rigidly in Indian criminal jurisprudence. The Court stated that if the core testimony inspires confidence, it can form the basis for conviction.
The Court rejected the appellants’ contention that the investigation’s defects warranted acquittal, noting that lapses in investigation do not automatically undermine the prosecution’s evidence, especially when eyewitness accounts are consistent and credible.
Regarding the accused convicted under the Explosive Substances Act, the Court found sufficient evidence to uphold the conviction, particularly the act of throwing a bomb without lawful justification.
The Court distinguished between accused acquitted and convicted, affirming that the trial and appellate courts correctly appreciated the evidence and assigned roles to each accused.
Conclusion
The Supreme Court dismissed the appeals and upheld the convictions and sentences of the accused persons convicted by the High Court. The judgment clarifies that:
Minor contradictions in witness statements do not vitiate the entire testimony if the core facts remain consistent.
Faulty investigation alone cannot be a ground for acquittal where evidence is otherwise reliable.
The courts must carefully separate credible evidence from inconsistencies and assess each accused’s role independently.
This ruling reinforces the principles of evidence evaluation in criminal trials and affirms that convictions can be sustained on the basis of reliable eyewitness testimony despite minor lapses in investigation or contradictions.
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