Chhattisgarh High Court
Criminal LawCriminal Procedure and Evidence

Concurrent findings of guilt warrant no revisional interference absent perversity or legal error.

TUKARAM SAHU vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 06, 20262 MIN READSOURCE JUDGMENT
Concurrent findings of guilt warrant no revisional interference absent perversity or legal error.. TUKARAM SAHU vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The complainant alleged that on 21 April 2013, the applicant entered her home, pushed her to the ground and caught hold of her; she raised an alarm, and her husband and son arrived, after which the applicant fled.

Source reference: para. 1–3

A charge-sheet followed. The Judicial Magistrate First Class convicted the applicant under Sections 451 and 354 of the Indian Penal Code (IPC), sentencing him to one year’s simple imprisonment and a fine of ₹1,000 under each section, with the sentences to run concurrently.

Source reference: para. 1–3

The Sessions Court dismissed his appeal and affirmed the conviction and sentence. The applicant challenged those concurrent findings in revision, arguing, among other things, that the complainant’s testimony was unreliable and the prosecution had not proved the offences beyond reasonable doubt

Source reference: para. 1–3

The High Court noted that he had already served the sentence

Source reference: para. 8
02

Issues

1. Whether the concurrent findings of guilt under Sections 451 and 354 IPC were unsupported by the evidence or otherwise warranted interference in revision

Source reference: para. 3, 6

2. Whether the applicant was required to surrender after dismissal of the revision, given that he had already served the sentence

Source reference: para. 8
03

Law Applied

The conviction was under Section 451 IPC, concerning house-trespass in order to commit an offence punishable with imprisonment, and Section 354 IPC, concerning assault or criminal force against a woman with the requisite intent or knowledge regarding the outrage of her modesty.

Source reference: no citation

In considering the revision, the Court stated that interference with concurrent findings was not warranted absent a demonstrated perversity, illegality, infirmity or error of law or fact

Source reference: para. 6

The judgment cites no precedent or further elaboration of the revisional standard

Source reference: no citation
04

Reasoning

The applicant challenged the complainant’s credibility, relied on alleged contradictions and prior enmity, and pointed to a prosecution witness who had turned hostile. The High Court did not separately analyse those evidentiary points or set out the elements of each offence; it concluded, after reviewing the trial and appellate judgments and the record, that the evidence had been properly appreciated and that the concurrent findings rested on cogent and adequate reasons. It therefore found no ground for revisional interference

Source reference: para. 3, 5–6

Since the applicant had already undergone the entire sentence, the Court held that he need not surrender.

Source reference: para. 8
05

Holding

The High Court dismissed the revision as devoid of merit and left the convictions and sentences under Sections 451 and 354 IPC undisturbed

As the applicant had already served the sentences, it directed that he was not required to surrender.

Source reference: para. 8
06

Acts & Sections Cited

2 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Indian Penal Code, 18602

Chhattisgarh High Court

Original Court PDF

TUKARAM SAHUvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 06, 2026

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