Conviction under IPC Sections 302 and 201 Confirmed; Circumstantial and Electronic Evidence Key in Upholding Verdict
Raipur, March 13, 2026 - In a significant judgment, the Chhattisgarh High Court has upheld the conviction and life imprisonment of Kusumlal Sao for the murder of Saurabh Panda, affirming the decision of the Additional Sessions Judge, Sarangarh. The court found that the prosecution successfully established a complete chain of circumstantial evidence pointing to Sao's guilt under Sections 302 and 201 of the Indian Penal Code (IPC).
The Division Bench, comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal, delivered the judgment, dismissing the appeal filed by Sao. The court observed that the prosecution's case was primarily based on circumstantial evidence, corroborated by electronic evidence retrieved from WhatsApp messages, which indicated a quarrel between Sao and the deceased.
The trial court had earlier convicted Sao based on medical evidence proving homicidal death, testimonies of witnesses, and the recovery of weapons used in the crime. Sao was found guilty of murdering Panda with an iron rod and a screwdriver, followed by an attempt to conceal the crime by abandoning the body in an isolated field.
The appellate court highlighted the significance of electronic evidence under Section 65B of the Indian Evidence Act, which played a crucial role in establishing the sequence of events leading to the crime. The messages indicated that Sao was the last person seen with Panda, thus strengthening the prosecution's case.
Moreover, the court noted that Sao failed to provide a plausible explanation for the injuries found on his body, which were consistent with the prosecution's narrative of a violent altercation. The court dismissed the defense's argument of accidental death due to a motorcycle fall, stating that the nature of the injuries and the location where the body was found clearly suggested otherwise.
In conclusion, the Chhattisgarh High Court affirmed the trial court's judgment, stating that the evidence presented formed an unbroken chain leading to Sao's guilt, leaving no room for any hypothesis of innocence. The court directed Sao to continue serving his sentence and informed him of his right to appeal to the Supreme Court.
Bottom Line:
Conviction under Sections 302 and 201 of IPC upheld by the appellate court based on circumstantial evidence forming a complete chain pointing towards the guilt of the accused.
Statutory provision(s): Sections 302, 201 of IPC; Section 65B of the Indian Evidence Act; Section 313 of the CrPC
Kusumlal Sao v. State of Chhattisgarh, (Chhattisgarh)(DB) : Law Finder Doc id # 2867244
