The maxim falsus in uno, falsus in omnibus-"false in one thing, false in everything"-finds its origins in Roman law. While its premise suggests that any falsehood in a witness's testimony undermines their entire account, Indian jurisprudence has eschewed its rigid application. This article critically examines the rejection of this doctrine by the Indian judiciary, with emphasis on recent judicial pronouncements, including T.G. Krishnamurthy v. State of Karnataka, 2023 SCC OnLine SC 874. The piece will also explore constitutional principles, statutory provisions, and relevant precedents, elucidating the nuanced approach of Indian courts toward evidence appraisal.

Introduction
The principle of falsus in uno, falsus in omnibus has often been venerated in jurisdictions where common law principles dominate. However, the Indian legal framework, which prioritizes justice over rigidity, has historically repudiated its wholesale application. Courts in India emphasize their duty to separate the credible from the incredible, ensuring that the quest for justice does not falter due to minor inconsistencies in testimony.

This departure from rigid adherence to falsus in uno underscores the judiciary's fidelity to Articles 14 and 21 of the Constitution, which guarantee equality before the law and protection of life and liberty, respectively. This article investigates the interplay between constitutional mandates, evidentiary rules, and the judiciary's cautious application of this doctrine.

Falsus in Uno: A Legal Overview

The maxim originated from Roman legal thought and was widely embraced in English common law. Its essence lies in the assumption that a witness found to be lying on one material fact is likely unreliable on others, rendering their testimony inadmissible. However, the Indian legal system has adopted a far more discerning approach. The principle is not codified in the Indian Evidence Act, 1872, which governs the admissibility, relevance, and evaluation of evidence. Instead, Indian courts have treated it as a rule of caution rather than a binding doctrine. Section 3 of the Evidence Act, which defines "evidence," obliges courts to weigh each piece of testimony judiciously.
 

Judicial Rejection of Falsus in Uno: Key Precedents

• Nisar Ali v. State of Uttar Pradesh, AIR 1957 SC 366: In this landmark decision, the Supreme Court unequivocally rejected the applicability of falsus in uno. It held that Indian courts must distinguish the falsehood from the truth within a witness's testimony rather than dismissing the entire evidence.
   
• Ugar Ahir v. State of Bihar, AIR 1965 SC 277: The Court reiterated that Indian courts are tasked with sifting credible evidence from falsehoods. The rejection of falsus in uno was deemed crucial to prevent the miscarriage of justice arising from minor discrepancies.
   
• T.G. Krishnamurthy v. State of Karnataka, 2023 SCC OnLine SC 874: The most recent reaffirmation of this principle came in T.G. Krishnamurthy. The Supreme Court held that falsus in uno has no application in Indian courts. It emphasized the judiciary's duty to meticulously separate "chaff from the grain" in its pursuit of truth. The Court observed:

  "A rigid application of falsus in uno would defeat the purpose of justice by enabling the rejection of substantive evidence on the ground of minor contradictions."

Constitutional and Statutory Framework

Constitution of India

• Article 14: The principle of equality before the law necessitates the impartial evaluation of evidence, ensuring that justice is not subordinated to inflexible doctrines.
• Article 21: The right to a fair trial, an essential component of the right to life and liberty, mandates that courts appraise evidence judiciously and in its entirety.

Indian Evidence Act, 1872

• Section 3: Mandates courts to evaluate the relevance and credibility of evidence, encouraging a balanced assessment rather than outright dismissal.
• Section 114 (Illustration g): While courts may presume adverse conclusions when evidence is withheld or falsified, this is discretionary and does not equate to automatic rejection of testimony.

Analysis: The Pragmatic Approach of Indian Courts

Indian courts have adopted a more pragmatic approach in rejecting the principle of falsus in uno. This methodology aligns with the realities of human behavior, recognizing that minor inconsistencies do not necessarily indicate falsehoods but may arise from lapses in memory or the stress of court proceedings.

Moreover, the Indian judiciary's stance ensures that justice is not compromised for procedural orthodoxy. This is particularly pertinent in cases involving vulnerable witnesses, such as survivors of sexual assault or marginalized individuals, where minor contradictions are often inevitable.

Conclusion
The rejection of falsus in uno, falsus in omnibus as a binding rule of law underscores the Indian judiciary's commitment to substantive justice over rigid formalism. By emphasizing the need to separate truth from falsehood within a witness's testimony, courts in India uphold the constitutional mandate of fairness and equality.

The principle's treatment as a rule of caution rather than a doctrinal imperative ensures that justice remains dynamic, contextual, and inclusive. The judgment in T.G. Krishnamurthy v. State of Karnataka, 2023 serves as a contemporary testament to this ethos, affirming the judiciary's unwavering pursuit of truth in the face of human fallibility.