Chhattisgarh High Court

Direct electronic evidence and scientific corroboration establish guilt in aggravated sexual assault and homicidal murder.

KISHAN YADAV vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 21, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant was convicted for the rape and murder of a 55-year-old mentally unstable woman

Source reference: para 4

On the intervening night of April 4–5, 2022, CCTV footage captured the Appellant dragging the deceased by her hair and assaulting her

Source reference: paras 6, 47

The deceased was later found with catastrophic injuries, including a fractured skull and a ruptured uterus resulting from the insertion of an iron rod

Source reference: paras 29, 30

Following a memorandum statement under Section 27 of the Evidence Act, the police recovered a blood-stained iron rod and clothing from the Appellant

Source reference: para 59

The Trial Court sentenced the Appellant to life imprisonment until natural death under Sections 376(2)(l)(m), 376(A), and 302 of the IPC

Source reference: para 3

The Appellant challenged the conviction primarily on the grounds of misappreciation of circumstantial evidence

Source reference: para 14
02

Issues

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

Source reference: para 18

2. Whether the circumstantial evidence, including the "last seen" theory and electronic evidence, establishes the guilt of the Appellant beyond reasonable doubt?

Source reference: para 34
03

Law Applied

The court applied Section 302 (Murder), Section 376 (Rape), Section 376(2)(l)(m) (Rape of a person with mental disability), and Section 376A (Rape causing death or persistent vegetative state) of the Indian Penal Code

Source reference: para 3

Procedurally, it applied Section 65-B of the Indian Evidence Act for the admissibility of electronic CCTV evidence

Source reference: para 15, 39

Section 27 regarding the discovery of facts based on an accused's disclosure

Source reference: para 57

The court relied on the Panchsheel principles of circumstantial evidence established in Sharad Birdhichand Sarda v. State of Maharashtra, requiring an unbroken chain of events

Source reference: para 35, 84

It further applied Section 106 of the Evidence Act regarding the burden of proving facts especially within one’s knowledge, as interpreted in State of Rajasthan v. Kashi Ram

Source reference: para 51
04

Reasoning

The Court found the medical evidence conclusive of homicidal death, noting multiple lacerated wounds and internal organ rupture caused by a blunt object

Source reference: para 29-33

Regarding the chain of circumstances, the Court held that the CCTV footage placed the victim in the exclusive company of the Appellant shortly before her death, invoking the "last seen" theory

Source reference: para 47-50

Under Section 106, the Appellant failed to offer any explanation for the victim's injuries or the presence of human blood found on his seized clothing and the iron rod

Source reference: para 52, 73

The Cyber Forensic Lab report authenticated the CCTV footage, identifying the Appellant and ruling out tampering

Source reference: para 45

The Court observed that the insertion of an iron rod fell squarely within the definition of rape under Section 375 IPC

Source reference: para 75, 100

Integrating the forensic, medical, and "last seen" evidence, the Court determined that the chain of circumstances was complete and inconsistent with any hypothesis of innocence

Source reference: para 78-79
05

Holding

The High Court dismissed the appeal and upheld the conviction and sentence of life imprisonment until natural death

The Court held that the prosecution successfully proved the Appellant's guilt through a complete chain of circumstantial evidence

Source reference: para 98-99

It further noted that the barbaric nature of the crime—targeting a vulnerable, mentally unstable woman—shocks the collective conscience of society and warrants the strictest judicial response

Source reference: para 100, 105

The Appellant remains in custody to serve his remaining term

Source reference: para 109
Chhattisgarh High Court

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KISHAN YADAVvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 21, 2026

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