The Chhattisgarh High Court, Division Bench of Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru, on 27 October 2025 dismissed an appeal by Suresh Sarkar (also known as Chhotu) and affirmed his conviction for the murder of constable Ram Niwas Markam. The court confirmed the trial court’s findings under Sections 302 and 201 of the Indian Penal Code, and ordered that the existing sentence life imprisonment along with fines and default terms continue to run.
The facts, as recorded in the judgment, recount how the deceased’s body was found on 12 July 2019 beside Supnar Road near a banana plantation; his Bolero vehicle was parked nearby with bloodstains under the back seat. Postmortem evidence concluded death was homicidal, caused by heavy hemorrhage from incised and lacerated injuries to the neck and head. The trial court had relied on a mix of scene evidence, forensic testing, telecommunications records and witness testimony to reach its verdict.
What moved the court away from reasonable doubt was the convergence of scientific indicators and supporting circumstances. Forensic analysis showed that hair strands clenched in the victim’s fist matched the DNA profile of the appellant’s blood sample, and a clear fingerprint recovered from a water bottle inside the vehicle matched the appellant’s print. Bloodstains were found on clothing and on items seized from the accused, and soil and other samples recovered at the scene contained human blood consistent with the prosecution’s theory of events. Taken together, the bench said, these links completed the chain of circumstantial evidence.
Defence arguments that evidence was improperly gathered or planted, that witnesses contradicted parts of the investigation, and that some seizure witnesses did not corroborate every detail were examined at length. The court engaged established precedent on circumstantial evidence and reiterated that suspicion, however strong, cannot substitute proof beyond reasonable doubt. Applying the “Panchsheel” of circumstantial proof and later Supreme Court guidance, the judges held that the prosecution had established every link necessary to exclude other reasonable hypotheses.
The bench also reviewed procedural aspects raised by defence counsel, including the conduct of certain seizure formalities and the timing of arrest and custodial actions. But on the balance of the record the forensic reports, call detail analysis showing sustained communications between the accused and the deceased on the day before the body was found, and corroborative witness testimony the High Court found no basis to disturb the trial court’s conclusions. The appeal was therefore dismissed and the trial court record was directed to be returned for compliance.
This judgment underscores how modern forensic tools (DNA profiling, fingerprint comparison and forensic serology) are being used alongside traditional circumstantial proof to build cases in violent-crime prosecutions. The court’s head-note emphasizes that scientific evidence can reliably establish identity and, when properly corroborated, close gaps in circumstantial chains.
Case Details : CRA No. 1584 of 2022, Suresh Sarkar @ Chhotu vs State of Chhattisgarh.
Counsels : For the Appellant : Mr. Ishwar Jaiswal, Advocate. For the Respondent : Mr. Hariom Rai, Panel Lawyer
Citation : 2025 Local Law (CG) 829
