The Supreme Court's decision in Darshan Singh v. State of Haryana (AIR 1997 SC 364) lays down a significant principle regarding the evaluation of conflicting evidence in criminal trials, particularly the interplay between medical evidence and eyewitness accounts. The judgment emphatically states that when there is an inconsistency between the evidence of a medical expert (like a doctor) and the unimpeachable testimony of an eyewitness on the crucial point of how an injury was caused, the latter holds greater evidentiary value and cannot be overridden by the former.

This ruling underscores the foundational role of direct sensory perception in judicial fact-finding and highlights the limitations of expert opinion when it contradicts credible firsthand accounts. This article will delve into the rationale behind this principle, its implications for criminal jurisprudence, and the nuances that courts must consider when faced with such evidentiary discrepancies.

The crux of the Darshan Singh judgment lies in the recognition that eyewitness testimony, when found to be credible and reliable, provides direct evidence of the occurrence and the manner in which the crime was committed. Eyewitnesses, being present at the scene, have the opportunity to observe the events as they unfold. Their account, if consistent and believable, forms a primary source of information for the court.
On the other hand, medical evidence, typically provided by doctors who examine the injured or deceased, is often in the nature of expert opinion based on their observations of the injuries and their understanding of medical science.

While medical evidence is undoubtedly crucial in corroborating the fact of injury, determining the cause of death, and providing insights into the nature and severity of wounds, it is essentially derivative evidence. Doctors usually arrive at their conclusions based on a post-mortem examination or the examination of the injured person, without having directly witnessed the incident itself.

The Supreme Court in Darshan Singh rightly emphasizes that when a direct, credible account from an eyewitness contradicts the inferences drawn by a medical expert regarding the manner in which the injury was inflicted, the eyewitness testimony should generally prevail. This is based on the fundamental principle that a person who has directly perceived an event is a more reliable source of information about the sequence of actions than an expert who reconstructs the event based on its physical aftermath.
The rationale behind this principle is multi-faceted:

• Direct Perception vs. Inference: Eyewitnesses provide direct evidence based on their senses, while medical experts offer opinions based on their interpretation of physical findings. Inferences, even scientifically informed ones, are inherently one step removed from direct observation and can be subject to alternative interpretations.
   
• Scope of Expertise: Medical expertise primarily lies in diagnosing injuries, understanding their physiological implications, and determining the cause of death from a medical standpoint. While they can offer opinions on the possible mechanisms of injury, they are not necessarily experts in reconstructing the precise sequence of events or the specific instrument used in the assault.
   
• Potential for Error: Medical opinions, while generally reliable, are not infallible. The appearance of injuries can sometimes be misleading, and different mechanisms might produce similar physical outcomes. Relying solely on medical opinion to contradict a credible eyewitness account risks overlooking the actual manner in which the injury occurred.
   
• Credibility of Witnesses: The judgment rightly qualifies this principle by stating that the eyewitness testimony must be "unimpeachable." If the eyewitness account is riddled with inconsistencies, improbabilities, or has been successfully challenged during cross-examination, its primacy may be called into question. The court must meticulously assess the credibility of the eyewitness before according it precedence over medical opinion.

However, it is crucial to avoid a simplistic application of this principle.

The court must carefully consider the nature of the inconsistency and the overall context of the evidence:

• Nature of Inconsistency: Minor discrepancies or ambiguities that do not fundamentally contradict the core of the eyewitness account may not be sufficient to disregard it. The inconsistency must pertain to the crucial point of how the injury was caused.
   
• Corroboration: While the eyewitness testimony is given primacy on the manner of injury, medical evidence remains vital for corroborating the fact of injury, its nature, and its consistency with the eyewitness account. If the medical evidence completely negates the possibility of the injury occurring in the manner described by the eyewitness, it could cast doubt on the veracity of the eyewitness.
   
• Expertise on the Instrument: In cases where the medical expert possesses specific expertise on the type of weapon used and the injuries it typically inflicts, their opinion might carry more weight, especially if the eyewitness account is vague or inconsistent with the known effects of such a weapon.
   
• Circumstantial Evidence: The court must also consider the totality of the circumstantial evidence in the case. If the circumstantial evidence strongly supports either the eyewitness account or the medical opinion, it can influence the court's assessment of the inconsistency.

The Darshan Singh principle serves as a crucial safeguard against allowing technical medical opinions to automatically override the direct and personal account of a witness who was present at the scene. It reinforces the importance of human testimony in the judicial process and acknowledges the unique value of firsthand observation.

In conclusion, Darshan Singh v. State of Haryana establishes a vital guideline for the evaluation of conflicting evidence in criminal trials. It underscores the primacy of unimpeachable eyewitness testimony over medical opinion, particularly on the crucial aspect of how an injury was caused. However, this principle must be applied judiciously, with a careful consideration of the credibility of the witness, the nature of the inconsistency, the corroborative value of the medical evidence, and the overall context of the case. The judgment highlights the delicate balancing act that courts must perform in weighing different forms of evidence to arrive at a just and accurate conclusion. It reaffirms that while expert opinion is valuable, it cannot supplant the direct and reliable account of someone who witnessed the crime firsthand.
 
Written By: Md.Imran Wahab, IPS, IGP, Provisioning, West Bengal
Email: imranwahab216@gmail.com, Ph no: 9836576565