evidentiary value of delayed and uncorroborated eye-witness testimony

The testimony of a sole eye-witness which suffers from unexplained delay in recording and material contradictions cannot form the sole basis for convicting an accused. Where a key witness claims to have witnessed a serious offense but remains silent for a considerable duration without a plausible or substantiated explanation, such delay severely tarnishes the credibility and trustworthiness of the witness. Allegations of persistent threats must be substantiated with concrete evidence showing how such threats operated to prevent the witness from reporting the crime to the authorities. Furthermore, when a witness contradicts their own prior statements made under procedural provisions, turns hostile regarding co-accused, or admits to not knowing the accused personally, such a witness exhibits the traits of a planted witness. Reliance on uncorroborated, delayed, and inconsistent eye-witness accounts violates the core principle of proof beyond reasonable doubt in criminal jurisprudence. Courts must exercise extreme caution and insist on independent material corroboration before accepting such testimony. (Tulasareddi @ Mudakappa & Anr. v. The State of Karnataka & Ors. | 2026 INSC 67)