Consistent eyewitness testimony corroborated by medical evidence sustains murder conviction despite absence of proven motive.

On 26 June 2015, Dwarik Sahani was allegedly sleeping outside his house after dinner when his son, Gandhi Sahani, attacked him with a knife.

Madhu Devi, the deceased’s daughter-in-law, claimed to have witnessed the appellant stabbing the deceased repeatedly, including on his chest, back, and other vital parts, resulting in his death.

The appellant was allegedly apprehended at the place of occurrence with the blood-stained knife, which was seized in the presence of witnesses.

The post-mortem examination recorded five incised injuries and attributed death to haemorrhage and shock caused by sharp-cut weapon injuries.

The appellant was charged under Section 302 of the Indian Penal Code, 1860, and was convicted by the Sessions Judge, Muzaffarpur, on 10 July 2017.

He was sentenced to imprisonment for life and a fine of ₹10,000, with two months’ rigorous imprisonment in default.

He challenged the conviction and sentence before the Patna High Court, alleging false implication arising from a family dispute and failure of the prosecution to establish motive.

Whether the prosecution proved beyond reasonable doubt that the appellant intentionally caused the death of Dwarik Sahani and was therefore guilty under Section 302 IPC?

Whether the absence of an established motive and the appellant’s plea of false implication created reasonable doubt warranting interference with the conviction?

Whether the life sentence and fine imposed by the trial court required appellate interference?

The Court applied Section 302 of the Indian Penal Code, 1860, which prescribes punishment for murder.

The prosecution was required to establish the appellant’s guilt beyond reasonable doubt through reliable and legally admissible evidence.

The Court relied on the settled principle that credible ocular testimony, when corroborated by medical evidence and surrounding circumstances, can sustain a conviction; motive is not indispensable where direct evidence satisfactorily proves the occurrence.

The Court also considered the evidentiary value of the recovery of the weapon from the accused and the medical opinion connecting the sharp-cut injuries with the cause of death.

The Court found the testimony of PW-1 to PW-5 consistent with the prosecution case and treated them as eyewitnesses to the occurrence.

The evidence of PW-3 specifically identified the appellant as the assailant and described the repeated knife attacks.

This ocular account was corroborated by the post-mortem evidence, which established multiple incised wounds and death from haemorrhage and shock caused by a sharp weapon.

The appellant’s apprehension at the scene with the knife and the seizure of that weapon further supported the prosecution version.

The Court held that the defence had failed to elicit any material contradiction or circumstance sufficient to discredit the prosecution witnesses.

The alleged absence of motive did not undermine the prosecution case because the direct eyewitness evidence, medical evidence, and recovery evidence proved the appellant’s involvement beyond reasonable doubt.

It found no error in the trial court’s appreciation of the evidence or in the sentence of imprisonment for life with a fine of ₹10,000, subject to two months’ rigorous imprisonment in default.

The appeal was accordingly dismissed, and the conviction and sentence were affirmed.