Firoz Khan Akbarkhan v. State of Maharashtra: Supreme Court Affirms Conviction for Murder

In a significant ruling, the Supreme Court of India upheld the conviction of Firoz Khan Akbarkhan for the murder of Sukhdeo Dhurve, reinforcing the importance of eyewitness testimony and the handling of discrepancies in criminal trials. The Court found that the prosecution had successfully proved its case beyond a reasonable doubt, dismissing the appellant’s claims of wrongful implication.

Introduction

The case of Firoz Khan Akbarkhan v. State of Maharashtra (2025 INSC 387) revolves around the conviction of the appellant for the murder of Sukhdeo Dhurve. The Supreme Court’s decision not only underlines the validity of eyewitness accounts but also clarifies the legal standards regarding discrepancies in testimonies. The Court confirmed the life imprisonment sentence imposed by the lower courts, maintaining that the evidence presented was sufficient to uphold the conviction.

Factual Background

The incident occurred on April 19, 2005, when a quarrel escalated into a violent confrontation resulting in Dhurve’s death. The prosecution argued that Akbarkhan, armed with a knife, inflicted fatal wounds on the deceased while his co-accused assisted in the attack. The Trial Court convicted Akbarkhan and another accused under Sections 302 (murder) and 34 (common intention) of the Indian Penal Code (IPC), sentencing them to life imprisonment.

Arguments Presented

Appellant’s Contentions

The appellant’s counsel argued that the prosecution’s case lacked reliability due to:

• Allegations of false implication based on community rivalry.
• Delayed recording of witness statements, suggesting manipulation.
• Inconsistencies in eyewitness accounts, raising doubts about their credibility.

Respondent’s Counterarguments

The state maintained that the lower courts had thoroughly examined the evidence, which included consistent eyewitness testimonies that confirmed Akbarkhan’s presence at the crime scene and his role in the murder. They argued that minor discrepancies in testimonies did not undermine the prosecution’s case.

Legal Reasoning

The Supreme Court’s analysis focused on several key points:

• Credibility of Eyewitness Testimony: The Court emphasized that the presence of eyewitnesses who consistently identified Akbarkhan as the perpetrator was crucial. Citing precedents such as State of Himachal Pradesh v. Lekh Raj, the Court ruled that minor discrepancies do not invalidate the overall reliability of witness accounts.
• Delay in Recording Statements: The Court found that the delay in witness statements was adequately explained by the chaotic circumstances surrounding the incident, namely communal riots. This was in line with prior rulings which indicated that context matters in evaluating delay.
• Intent and Premeditation: The Court rejected the argument for a lesser charge of culpable homicide, reinforcing that Akbarkhan’s premeditated use of a knife indicated intent to kill.

Implications of the Ruling

This ruling reaffirms the principle that a conviction can be sustained on the basis of consistent eyewitness accounts, even in the presence of minor inconsistencies. It also highlights the importance of contextual understanding regarding the timing of evidence collection, which can influence the credibility of witness testimonies.

Conclusion

The Supreme Court’s decision in Firoz Khan Akbarkhan v. State of Maharashtra serves as a reminder of the judiciary’s commitment to upholding justice based on credible evidence. The ruling reinforces the standards for evaluating eyewitness testimony and the treatment of discrepancies in criminal proceedings. Ultimately, the Court’s affirmation of the conviction underscores the rigorous scrutiny that must accompany the prosecution of serious offences like murder.