Landmark Judgements on Interested Witnesses
Interested Witnesses – Detailed Explanation
1. Meaning of Interested Witness
An interested witness is a person who has some kind of personal stake or interest in the outcome of a legal proceeding. This interest might be:
Financial gain or loss,
Relationship with the parties involved,
Personal enmity or bias,
Or any other motive that might affect the witness's testimony.
Because of this interest, the credibility of such witnesses is often scrutinized more rigorously.
2. Legal Position in Indian Evidence Law
The Indian Evidence Act, 1872 does not explicitly define the term "interested witness".
However, Section 3 of the Act defines a witness as a person who can make a statement about relevant facts.
The courts have, over the years, developed the principle that an interested witness’s testimony is not automatically inadmissible, but must be treated with caution.
3. Treatment of Interested Witnesses
The evidence of an interested witness is admissible.
It cannot be rejected solely because the witness is interested.
The court must evaluate the credibility, consistency, and corroboration of the testimony.
4. Distinction between Interested Witness and Related Witness
A related witness is a witness who is related to a party in the case but may or may not have a direct interest.
Being a related witness does not automatically make one interested.
An interested witness is someone who has a direct or indirect benefit from the outcome.
5. Important Landmark Judgments
(i) State of Rajasthan v. Kalkai (AIR 1981 SC 1390)
Facts: In this case, the Supreme Court considered the testimony of a witness who was related to the deceased.
Held: The Court held that merely being related to a party does not make a witness interested. A witness is interested only if he/she has a stake in the outcome of the case.
Significance: The Court clarified that the testimony of a related witness cannot be discarded solely on the ground of relationship.
(ii) Mohd. Rojali Ali v. State of Assam (2019) 19 SCC 567
Facts: The case dealt with the issue of whether a witness related to the victim was an interested witness.
Held: The Supreme Court observed that a related witness is not necessarily interested. The court emphasized that interest must be actual and not speculative.
Significance: The judgment reaffirmed the principle that the testimony of a related witness must be assessed on its own merits.
(iii) Pappu @ Matiuddin v. State of M.P. (Cr.A.No. 246 of 2010)
Facts: The appellant challenged the conviction on the ground that the prosecution’s main witness was related and interested.
Held: The High Court held that related witnesses do not have a propensity to falsely implicate an innocent person, and their evidence should be accepted if trustworthy.
Significance: This case highlights the care courts must take before discarding testimony simply on the ground of interest or relationship.
6. Principles for Evaluating Testimony of Interested Witnesses
Corroboration: Does independent evidence support the witness's testimony?
Consistency: Is the witness's story consistent internally and with other evidence?
Motive: Does the witness have any motive to falsify evidence?
Demeanor: How did the witness behave while testifying? Did they appear truthful?
7. Conclusion
The evidence of an interested witness is not unreliable per se.
Courts must examine such testimony with caution and consider the entire evidence in context.
Discarding testimony solely because the witness is interested or related would result in injustice.
It is the quality and reliability of the evidence that matters.
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