Murder conviction upheld based on circumstantial evidence of accused’s presence at the scene and immediate prior quarrel.

On August 24, 2017, a dispute regarding the unauthorized sale of paddy occurred between the appellant and his father (the deceased) at their residence

The appellant allegedly assaulted the deceased with his hands and fists and throttled him to death

Sanjay Sidar (PW-3), the appellant’s brother, filed the Merg intimation and subsequent FIR after being informed of the incident by locals

The trial court (1st Additional Sessions Judge, Raigarh) convicted the appellant under Section 302 of the IPC and sentenced him to life imprisonment

The appellant challenged the conviction, arguing that the case rested solely on circumstantial evidence and lacked eye-witness testimony

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

2. Whether the circumstantial evidence presented by the prosecution was sufficient to establish the appellant's guilt beyond a reasonable doubt

Section 302 of the Indian Penal Code (IPC) regarding murder

Section 374(2) of the Criminal Procedure Code (CrPC) regarding the right of appeal

The judgment also relied on the principle of circumstantial evidence, necessitating that the chain of circumstances be so complete as to leave no reasonable ground for a conclusion consistent with the innocence of the accused

The court affirmed the trial court's finding that the death was homicidal based on the postmortem report and the testimony of Dr. Vijay Lakda (PW-2), which revealed internal injuries including fractured ribs, a broken hyoid bone, and punctured lungs

Although no eyewitness saw the act of killing, the court found a robust chain of circumstances: the appellant was present in the house at the time of the incident

there was an established motive involving a dispute over paddy

a neighbor, Sahodara (PW-6), testified to seeing the appellant and deceased quarreling and being physically pushed by the appellant when she tried to intervene

The court observed that the injuries were consistent with hand-to-hand combat and noted that the appellant failed to establish an alibi or explain his presence elsewhere

The court held that the evidence clearly established that the appellant caused the death of his father during a physical altercation

The appellant was directed to serve the remainder of his sentence, with liberty to appeal to the Supreme Court