Tukesh Singh vs State of Chhattisgarh 2025 case gained attention due to the Supreme Court's close examination of procedural fairness in criminal trials. It highlighted concerns such as the reliability of witness identification in court and evidentiary value of contradictions under Section 162 of Criminal Procedure Code. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Tukesh Singh vs State of Chhattisgarh 2025 Introduction

Tukesh Singh vs State of Chhattisgarh 2025 is a landmark judgment which arose from a deadly property conflict that led to the brutal killing of two individuals and serious injuries to others in Masturi, Chhattisgarh. The accused were convicted of murder and related offences by the Trial Court and High Court which prompted an appeal before the Supreme Court.

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The case at hand centres around a violent property conflict involving the alleged unlawful possession of a shop in Masturi, Chhattisgarh. The conflict escalated into a brutal armed attack on 23rd March, 2001, resulting in the death of two individuals and serious injuries to several others. The Appellants were convicted for murder and attempt to murder by the Trial Court and the High Court which led to the present appeal before the Supreme Court. The following are the facts of Tukesh Singh vs State of Chhattisgarh -

Background and Initial Dispute

The incident arose from a property and loan dispute in the town of Masturi. Kashiram Rathore, a resident of Masturi, had borrowed money from Ganpat Singh. Unable to repay the loan, Kashiram handed over possession of his shop and the adjacent land to Ganpat Singh. Ganpat subsequently transferred the shop to his relative, Rajendra Singh (PW-11), who started a medical shop in the said property. Later, Rajendra Singh purchased both the shop and the adjoining land through a registered sale deed.

Incident of 23rd March 2001

On 23rd March, 2001, a group of nine individuals, including the present Appellants (accused nos. 1 to 8) and Ramesh Singh (accused no.9), allegedly attacked the medical shop with deadly weapons such as swords, rods, knives, poleaxes, clubs and wooden planks. The Prosecution alleged that the group acted with a common object and

• Killed: Manrakhan Singh and Narayan Singh.
• Attempted to kill: PW-1 Shivraj Singh, PW-3 Virendra Singh, PW-4 Judawan Singh, PW-5 Visheshwar Singh Thakur, and PW-8 Rakesh Singh Thakur, who were all injured eyewitnesses.

The First Information Report (FIR) was filed by PW-8 Rakesh Singh.

Police Investigation and Recovery

During the investigation, various weapons were reportedly recovered at the instance of the accused:

• A sword from Tukesh Singh (accused no.1).
• Another sword from Baba alias Rajesh Singh (accused no.3).
• A dagger with blood stains from Mangal Das (accused no.7).
• A club stained with blood from Pappu Singh (accused no.6).
• A wooden plank from Anil Singh (accused no.4).
• A metal rod from Vishnu Singh (accused no.5).

Trial Court and High Court Proceedings

The Trial Court convicted all nine accused under Section 147, Section 148, Section 307 r/w Section 149 and Section 302 r/w Section 149 of the Indian Penal Code, 1860. Each was sentenced to life imprisonment. 

Aggrieved by the decision of the Trial Court, the Appellants approached the Chhattisgarh High Court. However, the High Court of Chhattisgarh upheld the verdict of the Trial Court through its judgment dated 10th September, 2010.

Appeal Before the Supreme Court

The Appellants (accused nos.1 to 8) dissatisfied by the decision filed an appeal in the Supreme Court and challenged the decision of the Chhattisgarh High Court. The counsel of the Appellants in Tukesh Singh vs State of Chhattisgarh raised multiple contentions, including:

• A counter FIR was filed by Tukesh Singh the next day and alleged that the complainant's party was the aggressor. However, this counter-case was tried separately, which they argued caused prejudice.
• The delay in filing the FIR (by over 5 hours), despite the police station being very close to the scene.
• Injuries to the accused were not explained by the prosecution.
• Delay in recording statements of material witnesses PW-4 and PW-11.
• The eyewitnesses were related to the deceased and therefore they are "interested witnesses." Meanwhile, independent witnesses PW-13 to PW-15 did not support the prosecution.
• The version of events differed among the eyewitnesses on material points.
• A defence witness, Dr. Smt. Subhadra Painkra (DW-1), testified that accused no.9 (Ramesh Singh) was hospitalized during the time of the incident and was accompanied by accused no.8 (Tamesh Singh).

Tukesh Singh vs State of Chhattisgarh Response of the State

The State, represented by the Deputy Advocate General, defended the conviction in Tukesh Singh vs State of Chhattisgarh and asserted that:

• The injuries suffered by the accused were minor.
• There was no proof that the complainant’s group initiated the attack.
• Holding separate trials for the cross-case did not cause prejudice.
• The testimonies of injured eyewitnesses were credible and reliable.
• Minor inconsistencies in witness statements were not sufficient to discredit the overall prosecution narrative.

Tukesh Singh vs State of Chhattisgarh 2025 Legal Issues

The following issues were addressed in Tukesh Singh vs State of Chhattisgarh 2025 -

• Identification of Accused by Eyewitnesses

The main issue in this case was whether the failure of eyewitnesses to particularly identify the accused persons in court or ascribe a particular role to them in the commission of the offence affects the credibility and reliability of the case of the Prosecution.

• Value of Contradictions and Omissions in Witness Statements

The Supreme Court in Tukesh Singh vs State of Chhattisgarh examined the impact of material omissions and contradictions in the eyewitness testimony recorded during investigation and brought out in cross-examination, particularly in light of the explanation to Section 162 of Criminal Procedure Code, 1973.

On 14th May, 2025, the 3-Judge Bench of the Supreme Court comprising Justice Abhay S Oka, Justice Pankaj Mithal and Justice Ahsanuddin Amanullah in Tukesh Singh vs State of Chhattisgarh observed that although two eyewitnesses had deposed, during their cross-examination, it was revealed that while they pointed out that the accused were sitting in the courtroom, they failed to identify any specific individual or attribute any specific role to them in the commission of the offence. This lack of clear in-court identification severely weakened the case of the Prosecution.

The Court in Tukesh Singh vs State of Chhattisgarh noted that the cross-examinations revealed substantial omissions and contradictions in the eyewitness accounts. These contradictions were significant enough to fall within the scope of the explanation to Section 162 of the Criminal Procedure Code, 1973, which deals with inconsistencies in witness statements recorded during investigation.

The Appellants had already undergone a considerable portion of the sentence i.e., nine to ten years in custody before being granted bail. They had also remained on bail for approximately twelve years.

The Supreme Court in Tukesh Singh vs State of Chhattisgarh after carefully examining the evidence, the Court held that the Prosecution failed to prove the guilt of the accused beyond reasonable doubt. The inconsistencies and failure of the witnesses to identify the accused in court made it unsafe to base a conviction on such testimony.

Tukesh Singh vs State of Chhattisgarh Final Decision

The Supreme Court in Tukesh Singh vs State of Chhattisgarh set aside the impugned judgment dated 10th September, 2010 passed by the High Court of Chhattisgarh at Bilaspur.

• The Court acquitted the appellants/accused of all charges.
• Since they were already out on bail, the bail bonds were cancelled.
• Thus, the criminal appeals were allowed.

Conclusion

In Tukesh Singh vs State of Chhattisgarh 2025 the Supreme Court on 14th May, 2025 acquitted all the appellants. The Court cited serious discrepancies in witness testimonies and failure to identify the accused in court. The decision reaffirmed that convictions cannot be sustained on uncertain and unreliable evidence, especially in cases involving life sentences.