Chhattisgarh High Court

Conviction Quashed as Alleged Eye-Witnesses Failed to Corroborate Assault and Forensic Evidence was Lacking

BODYA ALIAS BODIYA MANJHI vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: June 29, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant was accused of murdering his father, Suknath, on December 12, 2018, by allegedly assaulting him with a bamboo stick

Source reference: p.2

Following the investigation and recording of a memorandum statement under Section 27 of the Evidence Act, the police seized a bamboo stick

Source reference: p.3

The Trial Court convicted the Appellant under Section 302 of the IPC based on the testimonies of two purported eye-witnesses, Ramsai (PW-01) and Kishun (PW-02), and sentenced him to life imprisonment

Source reference: p.3-4

The Appellant challenged this conviction, asserting that the prosecution failed to prove the charge beyond reasonable doubt as the witnesses did not actually see the assault

Source reference: p.4
02

Issues

1. Whether the death of the deceased was homicidal in nature?

Source reference: p.5 / para. 9

2. Whether the Appellant was the author of the crime based on the testimony of eye-witnesses and circumstantial evidence?

Source reference: p.6 / para. 10
03

Law Applied

The Court applied Section 302 of the Indian Penal Code (IPC) regarding the punishment for murder

Source reference: p.2

It relied on the evidentiary standards under the Code of Criminal Procedure (CrPC) for appreciating witness testimonies (Section 161) and memorandum statements

Source reference: p.6

The decision adhered to the fundamental criminal law principle that the prosecution must prove its case "beyond all reasonable doubt" to sustain a conviction

Source reference: p.7

Furthermore, it considered the procedural requirement of Section 437-A CrPC regarding bail bonds following an acquittal

Source reference: p.8
04

Reasoning

The High Court first affirmed the homicidal nature of the death based on the post-mortem report and medical testimony

Source reference: p.5

However, upon examining the evidence connecting the Appellant to the act, the Court found the Trial Court’s reliance on PW-01 and PW-02 to be "grave legal error"

Source reference: p.7

PW-01 admitted in cross-examination that he only heard a quarrel and did not see the assault

Source reference: p.6

PW-02 admitted he was not even in the village on the day of the incident and arrived two days later

Source reference: p.6-7

Regarding the recovery of the bamboo stick, the Court noted that the prosecution failed to provide an FSL report or evidence of human blood on the weapon to link it to the crime

Source reference: p.7

Consequently, the chain of circumstantial evidence was broken, and the eye-witness testimony was discredited

Source reference: p.7
05

Holding

The Court answered the first issue in the affirmative but the second in the negative. It held that the prosecution failed to prove the Appellant's guilt beyond reasonable doubt

The High Court set aside the conviction and sentence dated August 5, 2019, and acquitted the Appellant of the charge under Section 302 IPC by granting the benefit of doubt. The appeal was allowed, and the Appellant was discharged from his bail bonds subject to Section 437-A CrPC

Source reference: p.8
Chhattisgarh High Court

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BODYA ALIAS BODIYA MANJHIvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · June 29, 2026

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