10 February 2025 Acquittal >> Criminal Law   |   Criminal Appeals & Suspension of Sentence >> Criminal Law  

A man, Hansraj, imprisoned for over a decade for the murder of Ramlal in Ghotha Sakulpara, Chhattisgarh, has been acquitted by the High Court. Hansraj's initial conviction under Section 302 of the Indian Penal Code, along with a life sentence and fine, was based solely on circumstantial evidence. The trial court's decision, upheld initially by the High Court, has now been overturned due to significant flaws in the prosecution's case.

The incident occurred on March 28, 2002. The prosecution's narrative painted Hansraj as a disgruntled worker, alleging a motive stemming from unpaid wages. They claimed he was the last person seen with the deceased before Ramlal's wife, Budhiyarin Bai, discovered his body. Upon returning from the market, she testified to seeing Hansraj fleeing the scene with a farming tool, a farsi. This tool, later recovered, was purported to be the murder weapon.

However, the High Court scrutinized the prosecution's claims, finding them riddled with inconsistencies and weaknesses. The alleged motive of unpaid wages was deemed too trivial to incite such a violent act. Furthermore, the "last seen" theory was called into question. Witness testimonies regarding Hansraj's presence at the scene were contradictory and unreliable. While Budhiyarin Bai initially stated she didn't see him at the scene after her return, her testimony later shifted, claiming she saw him running with the farsi. Other witnesses also provided conflicting accounts of seeing a man fleeing, with no definitive identification of Hansraj.

The recovery of the farsi also faced scrutiny. While it bore bloodstains, no forensic analysis was presented to link the blood to the deceased. The High Court pointed out that similar tools are common in rural households, casting doubt on its definitive status as the murder weapon. Adding to the prosecution's woes, a witness statement contradicted the official narrative of the farsi's recovery, suggesting it was found in an open area rather than at Hansraj's behest.

The High Court emphasized the "panchsheel" principles established in Sharad Birdhichand Sarda vs State of Maharashtra, which govern the evaluation of circumstantial evidence. These principles require that the circumstances must be fully established, consistent with the accused's guilt, conclusive, and exclude any other reasonable hypothesis. Critically, the chain of evidence must be so complete as to leave no room for reasonable doubt about the accused's innocence.

In this case, the High Court found that the prosecution's evidence fell far short of these standards. The circumstances were not conclusively proven, and the possibility of Hansraj's innocence could not be excluded. The court concluded that the prosecution's case rested on speculation and conjecture rather than concrete evidence.

Consequently, the High Court overturned the lower courts' judgments, acquitting Hansraj of the murder charge. After spending over a decade in prison, he was finally released on bail and his name cleared. This case highlights the critical importance of rigorous scrutiny of circumstantial evidence and the need to ensure that convictions are based on proof beyond a reasonable doubt, not mere suspicion.

Section 302., Indian Penal Code - 1860  

Indian Penal Code, 1860