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Friday, May 31

Approver’s testimony needs corroboration is a proposition of law

Venkatesha vs State of Karnataka, Criminal Appeal No. 135 of 2005, Decided on January 8th, 2013
  

It was contended on behalf of the appellant that an approver’s evidence is unsafe for recording a finding of guilt against the accused unless the same is corroborated by other evidence in material particulars.

The Hon’ble Supreme Court held:

Section 133 of the Evidence Act, makes an accomplice a competent witness against the accused person and declares that a conviction shall not be illegal merely because it proceeds upon the uncorroborated testimony of an accomplice. Even so, the established rule of practice evolved on the basis of human experience since times immemorial, is that it is unsafe to record a conviction on the testimony of an approver unless the same is corroborated in material particulars by some untainted and credible evidence. So consistent has been the commitment of the courts to that rule of practice, that the same is now treated as a rule of law. Courts, therefore, not only approach the evidence of an approver with caution, but insist on corroboration of his version before resting a verdict of guilt against the accused, on the basis of such a deposition. The juristic basis for that requirement is the fact that the approver is by his own admission a criminal, which by itself makes him unworthy of an implicit reliance by the Court, unless it is satisfied about the truthfulness of his story by evidence that is independent and supportive of the version given by him. That the approver’s testimony needs corroboration cannot, therefore, be doubted as a proposition of law”. [Para 15]


The Court on the facts and circumstances of the case held:

“The High Court has, upon a careful and detailed reappraisal of the evidence, concurred with the view taken by the trial Court and, in our view, rightly held that there was sufficient corroboration to the version of the Approver, both in the form of oral depositions of the witness as also forensic evidence, that clearly support the prosecution case..” [Para 21]


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