Orissa High Court Acquits Prasanta Kumar Sahoo in Double Murder Case
Lack of Conclusive Evidence Leads to Acquittal in Circumstantial Evidence-Based Prosecution
In a significant judgment delivered on October 9, 2025, the Orissa High Court has overturned the conviction of Prasanta Kumar Sahoo in a double murder case involving his adoptive parents, Jadu Sahu and Pitei Sahu, in Khurda district. The court found that the prosecution failed to establish a complete chain of evidence that unerringly pointed to the guilt of the accused, resulting in his acquittal.
The trial court had previously sentenced Sahoo to life imprisonment for murder and five years for destroying evidence, following the deaths of Jadu and Pitei Sahu on the night of August 13, 1996. The prosecution's case relied heavily on circumstantial evidence, claiming that Sahoo, along with his second wife, Santilata, had committed the murders to acquire property from the deceased couple.
However, the High Court, led by Justice S.K. Sahoo and Justice Chittaranjan Dash, emphasized the necessity for a thorough and meticulous evaluation of circumstantial evidence. The judges found several gaps in the prosecution's case, notably the absence of motive and failure to exclude the possibility of an outsider's involvement in the crime. Furthermore, the court criticized the reliance on suspicions and conjecture rather than conclusive evidence.
The judgment highlighted several key issues with the trial court's findings. Firstly, the prosecution did not prove any motive for the crime, as the appellant was already adopted and had legal claims to the property. Secondly, the appellant's conduct following the discovery of the bodies, including his actions to call neighbors and report the incident to the police, was deemed natural and not indicative of guilt. Moreover, the appellant's absconding after the registration of a second FIR was not considered sufficient evidence of guilt.
The High Court also questioned the registration of a second FIR by the investigating officer, which was deemed irregular but not an illegality. The judges noted that the investigative process should have continued under the initial FIR filed by Sahoo, which was based on the same incident.
Ultimately, the court concluded that the prosecution's circumstantial evidence did not form a complete and unbroken chain leading to the exclusive conclusion of Sahoo's guilt. The judgment serves as a reminder of the high standard required for conviction based solely on circumstantial evidence, underscoring that suspicion cannot substitute for proof beyond a reasonable doubt.
This decision marks a pivotal moment in the case, as Sahoo, initially convicted on serious charges, is now acquitted due to lack of legal proof. The ruling is expected to impact future prosecutions based on circumstantial evidence, reinforcing the need for comprehensive and conclusive evidence to support convictions.
Bottom Line:
Conviction in a case based on circumstantial evidence requires the prosecution to prove a complete chain of evidence, which excludes all reasonable hypotheses other than the guilt of the accused - Absence of motive and failure to establish a complete chain of circumstances in a murder case can lead to acquittal.
Statutory provision(s):
- - Indian Penal Code, 1860, Section 302 and 201
- - Indian Penal Code, 1860, Section 34
- - Evidence Act, 1872, Sections 8 and 106
- - Criminal Procedure Code, 1973, Section 154
Prasanta Kumar Sahoo v. State of Odisha, (Orissa)(DB) : Law Finder Doc Id # 2791457
