Citation : 2025 Local Law (CG) 862 : 2025:CGHC:54999-DB
The Chhattisgarh High Court at Bilaspur has partially allowed an appeal and reduced a murder conviction to the lesser offence of grievous hurt, while keeping the accused’s conviction for concealment of a body intact. In a bench judgment delivered on November 12, 2025, Justices Rajani Dubey and Amitendra Kishore Prasad held that the medical and testimonial evidence established homicidal injury but did not support a finding that the single blow inflicted was sufficient in the ordinary course of nature to constitute culpable homicide. The full judgment and operative order were reserved on August 20, 2025 and uploaded on November 12, 2025.
The case arose from the death of Manoj, whose body was discovered by villagers on August 3, 2016. The trial court had convicted Ramkumar (also known as Binjkotiya) under Sections 302 and 201 of the Indian Penal Code and sentenced him to life imprisonment for murder, along with a concurrent sentence for tampering with a dead body. On appeal the High Court reviewed the medical evidence, witness testimony and the sequence of events and concluded that while the injuries were homicidal and were caused by a blunt instrument, the injury pattern and circumstances pointed to grievous hurt rather than an offence attracting Section 302.
The court noted that the postmortem report described fractures and significant bleeding, and that eye witnesses initially described the accused assaulting the deceased with a club. However, the High Court emphasized that the medical evidence did not demonstrate the kind of fatal injury in ordinary course that would mandate conviction for murder. Relying on established precedents dealing with single-blow head injuries and the scope of sections 302 and 325 IPC, the bench altered the conviction from Section 302 to Section 325, while maintaining the conviction under Section 201 for disposal of the body.
Because the appellant had already spent nearly three years in custody from August 7, 2016 to April 24, 2019, the High Court set his sentence to the period already undergone, effectively releasing him from additional imprisonment on the modified conviction. The court also directed that the appellant, who was reported to be on bail, must furnish a personal bond of Rs. 25,000 under section 481 of the BNSS 2023 for a period of six months and give an undertaking to appear before the Supreme Court if a special leave petition is filed against the judgment. The trial court record was ordered returned for compliance and further action.
This judgment illustrates the careful line courts draw when differentiating between offences that attract the most serious penal consequences and those that do not, particularly where a single blow to the head produces severe but not conclusively fatal injuries in the ordinary course of nature. The High Court’s approach rested on a combined reading of forensic findings and witness statements and on precedents that require careful calibration of criminal liability to the actual causal nexus between injury and death.
Case Details : CRA No.845 of 2017, Ramkumar @ Binjkotiya vs State of Chhattisgarh
Counsels : For Appellant (s) : Ms. Sareena Khan, Advocate. For Respondent(s) : Mr. Ashutosh Shukla, Advocate