Chhattisgarh High Court quashes life sentences in 2013 death case after doubts over evidence
The Division Bench of the High Court of Chhattisgarh quashed convictions and life sentences imposed in a 2013 death case, concluding that the evidence did not reliably prove that the accused had murdered the victim.
The court heard two connected appeals that challenged an Additional Sessions Judge’s 2014 conviction of several men for offences including murder under Section 302 read with Section 149 of the Indian Penal Code. The trial court had sentenced the accused to life imprisonment, but the High Court found serious gaps in the prosecution’s story and overturned the judgment.
At the heart of the decision was the court’s assessment of the prosecution’s evidence. The High Court found the sole eye witness to be inconsistent and implausible, noting material omissions and contradictions in his account. Medical records and the initial medical legal case report indicated that the injured man had been examined as a road accident victim and was conscious at the time of that examination. The postmortem, while recording multiple injuries and complications that led to cardio respiratory failure, did not identify wounds that would have prevented the deceased from riding a motorcycle. Taken together, these facts, and the witnesses’ failure to report or complain promptly, led the bench to conclude that the prosecution had not proved guilt beyond reasonable doubt.
The High Court also scrutinised alleged dying declarations and statements recorded by police. It observed procedural and factual problems, including inconsistencies with medical testimony about the deceased’s condition, which undermined the reliability of those statements. Citing settled Supreme Court principles on the caution required when relying on solitary or oral dying declarations, the bench said the statements did not meet the test of being wholly trustworthy and voluntary.
The court followed precedent on assessing the quality of eyewitness and dying-declaration evidence. It emphasised that if the prosecution’s key witness is found to be improbable or fabricated, conviction cannot safely rest on that testimony alone unless independent and reliable corroboration exists. In this case the corroboration was lacking and the medical and investigative record raised reasonable doubt.
As a result, the High Court allowed both appeals and set aside the trial court’s conviction and sentences. The accused, who were reported to be on bail, were directed to furnish personal bonds of Rs. 25,000 each with one surety of the same amount, effective for six months, together with an undertaking to appear if the state files a special leave petition. The court also directed the trial court registry to receive the record and implement the order.
This judgment highlights a recurring tension in criminal trials between prompt medical reporting, witness conduct, and the timing and content of police records. When the medical record points to accidental injury and key witnesses delay or contradict earlier statements, courts are likely to scrutinise the prosecution narrative closely. The High Court’s ruling underscores that reasonable doubt must always favour the accused when the evidentiary foundation is uncertain.
Case Details : CRA No. 821 of 2014, Manish Soni and Others vs State of Chhattisgarh. with CRA No. 1161 of 2014, Vishwajeet Rai vs State of Chhattisgarh. For the appellants in CRA No. 821/2014 : Mrs. Indira Tripathi, Advocate. For the appellant in CRA No. 1161/2014 : Mrs. Fouzia Mirza, Senior Advocate appears along with Mr. Ali Afzal Mirza, Advocate. For the Respondent/State : Mr. Ajay Pandey, G.A.