NARAIN AND TWO OTHERS vs THE STATE OF PUNJAB

The Supreme Court held that the failure to examine a material witness, R, did not vitiate the trial under Section 167 of the Indian Evidence Act, 1872. The Court ruled that R was not a material witness as he arrived after the assault, and thus his absence did not affect the fairness of the trial. The High Court's decision to uphold the convictions was affirmed, establishing that a witness is material only if essential to the prosecution's narrative.