Chhattisgarh High Court dismisses appeal and upholds life sentences in a Bemetara murder case, affirming a complete chain of circumstantial evidence

Justice Bibhu Datta Guru

News Citation : 2025 LN (HC) 2

Bilaspur, June 30, 2025 : The High Court of Chhattisgarh has upheld the life sentences awarded to two young men convicted for a brutal murder in Bemetara district, dismissing their criminal appeal and affirming that the prosecution successfully proved a complete chain of circumstantial evidence.

A Division Bench headed by Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru delivered the judgment on June 30, 2025, rejecting the appeal filed by Rahul Sahu and Sesh Kumar alias Sajan against their conviction by a sessions court in October 2023. Both appellants had been sentenced to life imprisonment for murder, along with additional terms for criminal conspiracy and destruction of evidence.

The case arose from the killing of a young man whose body was found near Moharangiya Nala in December 2022. The prosecution alleged that the murder was the result of a pre-planned conspiracy involving the two appellants and a third accused who was a juvenile at the time, whose trial was separated. The victim had last been seen in the company of the juvenile accused on the night he went missing.

Before the High Court, the defence argued that the case rested entirely on circumstantial evidence and suffered from serious procedural lapses. A key challenge was directed at the collection of voice samples from the accused without prior permission from a magistrate. It was also argued that recoveries of mobile phones and other materials were unreliable, and that the SIM cards allegedly used were not registered in the appellants’ names.

The Bench, however, found these submissions unconvincing. It held that the prosecution had established every crucial link: the homicidal nature of the death, the “last seen” evidence, a clear motive rooted in personal relationships, recoveries made pursuant to memorandum statements, forensic corroboration, and voice analysis reports that matched the appellants with recorded conversations planning the crime. The Court noted that the accused had voluntarily consented to providing voice samples and had never objected to the procedure during trial or in their statements under Section 313 of the Criminal Procedure Code.

Addressing the argument on procedural defects, the Court observed that minor lapses in investigation do not automatically entitle an accused to acquittal, particularly when no prejudice is shown and the overall evidence points decisively to guilt. It concluded that the conspiracy to murder was clearly established and that the actions of the appellants demonstrated a shared intention to kill the victim and conceal evidence.

With these findings, the High Court dismissed the appeal and directed that the appellants, who are already in custody, continue to serve their remaining sentences. The judgment also clarified that the convicts are free to challenge the decision before the Supreme Court with legal aid, if they so choose.

Case Reference : CRA No. 2134 of 2023, Rahul Sahu vs State of Chhattisgarh; Counsel for the Appellants: Mr. Uttam Pandey, Mr. R. R. Dwivedi and Ms. Pooja Sinha, Advocates; Counsel for the Respondent: Mr. Shangarsh Pandey, Deputy Government Advocate.

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