Piara Singh & Ors. v. State of Punjab AIR 1977 SC 2274

PIARA SINGH & ORS V. STATE OF PUNJAB

Whether the High Court correctly prioritized the medical opinion of Dr. Jatinder Singh, who performed the post-mortem, over Dr. Paramjit Singh’s conflicting expert testimony?
Whether the High Court was justified in reversing the Sessions Court’s acquittal based on the available evidence?
Whether the evidence of an extra-judicial confession be corroborated?

Expert Testimony and Conflicting Medical Evidence: When two expert medical opinions conflict, the court generally prefers the testimony that aligns with direct evidence if it is reliable. Medical opinion serves to corroborate rather than supersede direct eyewitness accounts.

On November 14, 1967, Surjit Singh was attacked by four appellants who had broken into his home with weapons.
One of them, namely Piara Singh, was armed with a rifle and fired it, as a result of which the deceased fell and died soon after.
The appellants were charged when a chargesheet was filed against them; they were brought before the court of sessions, put on trial, and ultimately found not guilty by the Learned Trial Judge.
The appellant made an extra-judicial confession to one of the witnesses, admitting having murdered the deceased.
On appeal to the High Court, they were of the view that the judgment of the Learned Sessions Judge was wrong and convicted the appellants.
The injury’s nature made it very evident that it was a firearm injury that a rifle may have caused, along with positive evidence that Piara Singh had shot the rifle
The High Court noted that, given the differences in opinion between the two experts, the doctor who had the initial benefit of being able to examine the deceased, perform a postmortem, and determine the type of injury viewpoint is more valuable than the Sessions Court doctor who did not have this privilege.

The Supreme Court upheld the High Court’s conviction, noting:
The High Court was justified in reversing the acquittal based on credible evidence that included eyewitness testimonies, corroborative medical evidence, ballistic expert findings, and an extra-judicial confession by Piara Singh.
The medical testimony by Dr. Jatinder Singh, who conducted the post-mortem, was preferred over the conflicting opinion of Dr. Paramjit Singh, who had not seen the body.
It was reasonable to accept evidence from interested or inimical witnesses, as they were credible eyewitnesses due to their proximity and immediate reporting.
The extra-judicial confession, corroborated by other evidence, was admissible without needing further corroboration.
Overall, the Court found the evidence against the accused sufficient to support the charge of murder. The appeal was dismissed, affirming the High Court’s decision.