The Supreme Court of India set aside the murder conviction in Govind Mandavi v. State of Chhattisgarh, holding that failure to name a known accused in the FIR is a crucial omission that seriously weakens the prosecution’s case. The appellant had been convicted for murder based mainly on the testimony of the deceased’s wife, who claimed to be an eyewitness. However, the FIR lodged by the deceased’s father described the assailants as two unknown masked persons and did not name the appellant. The Court noted that although the witness later claimed she identified the accused when his mask fell and by his voice, this vital fact was absent from the FIR, despite other details being carefully recorded. The Court further found the eyewitness testimony unreliable, as the accused was named for the first time four days later in a Section 161 CrPC statement, and the witness made material improvements during trial. The Test Identification Parade was held after the accused was already named, rendering it meaningless. Recovery of blood-stained articles was also inconclusive, as the blood group could not be matched with the victim. Holding that the prosecution failed to prove guilt beyond reasonable doubt, the Supreme Court acquitted the appellant and ordered his release.