The Chhattisgarh High Court has refused to disturb a trial court’s acquittal in a case that began with a neighbourhood dispute over household waste. In a short but pointed judgment delivered on October 10, 2025, Justice Radhakishan Agrawal dismissed the State’s appeal in ACQA No. 176 of 2017, upholding the Special Court’s finding that the prosecution failed to prove caste-based abuse and threats beyond reasonable doubt.
The facts are simple. The complainant, Mohan Mandavi, alleged that on June 12, 2015 the respondents Yogeshwar and Chandrakiran Sahu, residents of Govindpur village in North Bastar dumped household garbage into a drain in front of his house, and then abused and threatened him in caste-based terms when he objected. The police investigation produced an FIR, seizure of the complainant’s caste certificate, a spot map, and the custodial records of the accused. The prosecution called eleven witnesses and produced 15 documents; the defence led no oral witnesses and tendered two documents.
But the High Court agreed with the trial judge’s careful evaluation of the evidence. The court emphasized inconsistencies between the complainant’s oral testimony and his written report, noting omissions on critical points for example, the written report did not record certain details the complainant later mentioned in court, such as the specific caste-based words used or the complainant’s son fetching an iron rod. The complainant had also admitted that he stayed on the third floor and did not come down to the ground level at the time of the alleged incident. Several prosecution witnesses either gave only general accounts of shouting between neighbours or did not support allegations of caste insults and life threats.
Applying settled law on appeals against acquittal, the High Court reiterated that an appellate court must be cautious about upsetting an acquittal where the trial court’s view is a possible, reasoned one. Quoting the Supreme Court’s guidance in Jafarudheen v. State of Kerala, the High Court explained that acquittal carries a strong presumption of innocence and can be reversed only after thorough scrutiny under accepted legal parameters. Having applied that standard, the court found no ground to disturb the trial court’s conclusion that the prosecution had not proved caste-based abuse or threats beyond reasonable doubt, and dismissed the State’s appeal.
The judgment highlights two recurring themes in criminal litigation: the importance of internal consistency between FIRs and later testimony, and the difficulty of proving offences that turn on specific words or short, contested episodes between neighbours. Where reports and testimony diverge, and independent witnesses do not corroborate critical allegations, courts are likely to treat the prosecution’s case as fragile. For public authorities, the ruling serves as a reminder to ensure prompt, detailed and contemporaneous documentation where sensitive offences are alleged; for litigants, it underscores the centrality of credible, consistent evidence when the charge is serious.
Citation : 2025 Local Law (CG) 836
Case Details : ACQA No. 176 of 2017, State of Chhattisgarh vs. Yogeshwar Sahu and Ors.
Counsels: For Appellant/Petitioner/Plaintiff: Surendra Kumar Dewangan, Panel Lawyer. For Respondents/Defendant: Parag Kotecha, Advocate.
Acts/Rules/Orders: Code of Criminal Procedure, 1973 (CrPC) [repealed] – Section 378; Indian Penal Code 1860, (IPC) [repealed] – Section 294; Indian Penal Code 1860, (IPC) [repealed] – Section 506; Scheduled Castes And The Scheduled Tribes (prevention Of Atrocities) Act, 1989 – Section 3(1)
Cases Referred: Jafarudheen and Ors. vs. State of Kerala