Supreme Court of India· 08 September 2026

Does the maxim falsus in uno, falsus in omnibus apply in criminal trials in India?

Santosh Singh v. The State of Madhya Pradesh and Ors

2026 INSC 972 · Criminal Appeal No.1306 of 2022
Coram: Justice J. B. Pardiwala · Justice K. Vinod Chandran

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Answer

The maxim falsus in uno, falsus in omnibus does not apply in criminal trials in India.

No. The maxim falsus in uno, falsus in omnibus is not applicable in India; the Court has a duty to separate the truthful ('grain') part of a witness's testimony from the false ('chaff'), rather than rejecting the whole of it for one falsehood. (¶26)

Headnote

Indian Penal Code, 1860 — s.34, s.149 — Unlawful assembly — Common intention — Related witnesses — Falsus in uno falsus in omnibus — IPC — s.34, s.149 — Presence in unlawful assembly — Held: An accused proved to be part of an unlawful assembly need not have fired the fatal shot to be convicted on common intention or object under Section 34 or Section 149 IPC. (¶8) Evidence — Appreciation of testimony — Falsus in uno falsus in omnibus — Held further: The maxim falsus in uno, falsus in omnibus does not apply in criminal trials in India; the Court must separate the truthful part of a witness's testimony from the false. Appeal against A6 and A12 allowed; A13's acquittal sustained. (¶26, 27)

Headnote

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In the Court's own words

Paragraph 26The principle of ‘falsus in uno, falsus in omnibus’ is not applicable to India and as has been famously held, here, the Courts have a duty to separate the grain from the chaff in analyzing evidence. Carrying out such a measure, we are inclined to find the presence of A1, A6 and A13 as spoken of by PW1, PW10 and PW11 at the incident spot and the shooting having occurred as narrated by them. The medical evidence provides enough corroboration for the death having occurred, as spoken of by the witnesses and PW1’s testimony being truthful, corroborated by the injury sustained by him as spoken of by PW3, the Doctor. But the others were added without just cause and in that context we cannot but notice, that after the shooting of her son, the mother of the victim passed away, almost simultaneously, out of shock or by suicide, is not clear.

Acts & Sections

s.34 Indian Penal Code, 1860s.149 Indian Penal Code, 1860s.302 Indian Penal Code, 1860s.319 Code of Criminal Procedure, 1973

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Also decided in this judgment

Must an accused proved to be part of an unlawful assembly have fired the fatal shot to be convicted on common intention or object?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections