Bilaspur : The Chhattisgarh High Court has upheld the life imprisonment of a man convicted of murdering a youth in Sarangarh-Bilaigarh district, finding that the chain of circumstantial and forensic evidence clearly established his guilt.
In a judgment delivered on March 13, 2026, a division bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal dismissed a criminal appeal filed by Kusumlal Sao. The appeal challenged the March 30, 2024 decision of the Additional Sessions Judge, Sarangarh, which had convicted Sao under Sections 302 (murder) and 201 (causing disappearance of evidence) of the Indian Penal Code and sentenced him to life imprisonment.
The case relates to an incident from February 2019, when the body of Saurabh Panda was found in an agricultural field in village Sanda. At first, some villagers believed the death might have been caused by a road accident because a motorcycle was found near the body. However, the police investigation later revealed that the victim had been violently assaulted.
During the investigation, police recovered several important pieces of evidence. Blood-stained soil was seized from the accused’s house, along with a shirt belonging to him that also had blood stains. Investigators also recovered two suspected weapons — a metal die and a screwdriver — from the roof of the accused’s house. These items were sent for forensic examination.
Medical evidence strongly supported the prosecution’s case. The post-mortem examination found multiple injuries on the victim’s head, neck and face. Doctors noted a serious head injury with a skull fracture and exposed brain tissue. The cause of death was determined to be cardio-respiratory arrest resulting from a severe head injury, and the doctor clearly stated that the death was homicidal.
Electronic evidence also emerged during the investigation. A WhatsApp message sent shortly after the incident suggested that a quarrel had taken place between the accused and the victim on the night of February 7, 2019. Cyber forensic records further indicated that the deceased was last seen with the accused before his death.
The court also took note of injuries found on Kusumlal Sao during his medical examination, including abrasions on his fingers and head. The judges observed that the accused failed to provide any explanation for these injuries, which further strengthened the prosecution’s case.
Another important circumstance was the location where the body was found. The body was lying in the middle of an agricultural field where a motorcycle could not normally reach without deliberate human effort. The court observed that this indicated the body had likely been transported and dumped there after the assault.
Although some witnesses did not fully support the prosecution during the trial, the court noted that minor contradictions or hostile witnesses do not automatically weaken the entire case. The judges said courts can rely on those parts of witness testimony that remain consistent with other reliable evidence.
After examining the entire record, the High Court concluded that the prosecution had successfully established a complete chain of circumstances. These included the homicidal nature of the death, evidence of a quarrel between the accused and the victim, last-seen evidence supported by electronic records, recovery of suspected weapons, unexplained injuries on the accused, and the dumping of the body in a remote field.
The bench held that these circumstances clearly pointed to Kusumlal Sao as the person responsible for the crime and ruled out any reasonable possibility of innocence. The appeal was therefore dismissed and the life sentence imposed by the trial court was upheld.
The court also noted that the accused has been in custody since February 11, 2019 and will continue to serve his sentence. However, he has the right to challenge the judgment before the Supreme Court with the assistance of legal services authorities.
Case Reference: CRA No. 1482 of 2024, Kusumlal Sao S/o Chakradhar Sao vs State of Chhattisgarh.