Presence at the scene and admission of assault do not prove murder without reliable identification.

The prosecution alleged that an unidentified person attacked and killed Rohan Mahto at his shop with a fawda and injured P.W.-1, Chaitu Hansda, who later became unconscious.

The appellant was reportedly apprehended by residents of nearby hutments because his clothes bore bloodstains, but none of those residents testified at trial.

The trial court convicted the appellant under Sections 302 and 324 of the Indian Penal Code (IPC), sentencing him to life imprisonment for murder and two years’ rigorous imprisonment for causing hurt.

In appeal, the High Court considered, among other matters, P.W.-1’s account and identification, the absence of medical evidence of his injury, the investigation, and the forensic evidence concerning the appellant’s clothes.

Whether the evidence established beyond reasonable doubt that the appellant committed the murder punishable under Section 302 IPC.

Whether the evidence established the appellant’s guilt under Section 324 IPC for injuring P.W.-1.

The Court considered the offences under Sections 302 and 324 IPC and assessed whether the prosecution evidence proved the appellant’s guilt.

It applied the principle that reasonable doubt arising from the evidence must be resolved in favour of the accused.

The Court also considered the appellant’s statement under Section 313 of the Code of Criminal Procedure (CrPC), in which he denied committing murder but admitted being present and assaulting one person; that statement was considered alongside the other evidence and did not, by itself, establish the murder charge.

No precedent was cited.

The Court found P.W.-1’s account insufficient to establish that he witnessed the murder: his evidence suggested he may have been assaulted first and became unconscious, and he stated that he could not identify his assailant, notwithstanding his later identification of the person in the dock.

The persons said to have apprehended the appellant were not examined, the investigating officer had not recorded statements from other shopkeepers, the murder weapon was not recovered, and the FSL report established only that the clothing bore human blood—not whose blood it was.

The prosecution also produced no doctor or medical report to substantiate P.W.-1’s injury.

Although the appellant admitted being present and assaulting someone, the Court found no material connecting him to the deceased’s murder; the evidentiary deficiencies also left the prosecution case as a whole in reasonable doubt.

It acquitted the appellant, allowed the appeal, and directed his release forthwith unless he was wanted in another case.