News Citation : 2026 LN (HC) 198 | 2026:CGHC:12087-DB
March 13, 2026 : The Chhattisgarh High Court has upheld the life imprisonment of a man convicted for the murder of a youth in Sarangarh-Bilaigarh district, ruling that the chain of circumstantial and forensic evidence clearly proved his guilt beyond reasonable doubt.
In a detailed judgment delivered on March 13, 2026, a division bench of Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal dismissed the criminal appeal filed by Kusumlal Sao, who had challenged his conviction for the murder of Saurabh Panda. The appeal was filed against the March 30, 2024 judgment of the Additional Sessions Judge, Sarangarh, which had found Sao guilty under Sections 302 (murder) and 201 (causing disappearance of evidence) of the Indian Penal Code and sentenced him to life imprisonment.
The case dates back to February 2019 when the body of Saurabh Panda was discovered in an agricultural field in village Sanda. Initially, some villagers suspected that Panda might have died in a road accident after a motorcycle was found near the body. However, the police investigation revealed signs of a violent assault.
According to the prosecution, the investigation uncovered several key pieces of evidence, including blood-stained soil from the accused’s house, a shirt belonging to the accused with blood stains, and two alleged weapons a metal die and a screwdriver recovered from the roof of the accused’s house. These items were seized during the investigation and sent for forensic examination.
Medical evidence played a crucial role in the case. The post-mortem conducted by the doctor found multiple injuries on Panda’s head, neck and face, including a severe head wound with a fracture of the skull and exposed brain tissue. The doctor concluded that the cause of death was cardio-respiratory arrest due to severe head injury and clearly stated that the death was homicidal in nature.
During the investigation, electronic evidence also surfaced. A WhatsApp message allegedly sent shortly after the incident indicated that a quarrel had taken place between the accused and the victim on the night of February 7, 2019. Cyber forensic records retrieved by the police supported the claim that the deceased had last been seen with the accused shortly before his death.
The prosecution also pointed to injuries found on Kusumlal Sao during his medical examination, including abrasions on his fingers and head. The court noted that the accused had failed to provide any explanation for these injuries, which further strengthened the prosecution’s case.
Another significant factor considered by the court was the location where the body was found. The body was discovered in the middle of an agricultural field where a motorcycle could not normally reach without deliberate human intervention. The court observed that this strongly suggested the body had been transported and dumped there after the assault.
While some witnesses did not fully support the prosecution during the trial, the court emphasized that minor contradictions or hostile testimony do not automatically invalidate the prosecution’s case. The judges noted that courts are allowed to rely on those portions of witness testimony that are consistent with other credible evidence.
After reviewing the entire record, the High Court concluded that the prosecution had successfully established a complete chain of circumstances. These included the homicidal death, evidence of a quarrel between the accused and the victim, last-seen evidence supported by electronic records, recovery of the suspected weapons, unexplained injuries on the accused, and his conduct in abandoning the body in an isolated field.
The bench ruled that these circumstances clearly pointed to Kusumlal Sao as the perpetrator and ruled out any reasonable possibility of innocence. As a result, the court dismissed the appeal and affirmed the life sentence imposed by the trial court.
The court also noted that the accused has been in custody since February 11, 2019 and will continue to serve his sentence. At the same time, it informed him of his right to challenge the judgment before the Supreme Court with the assistance of legal services authorities.
Case Reference : CRA No. 1482 of 2024, Kusumlal Sao S/o Chakradhar Sao vs State of Chhattisgarh; Counsel for Appellant: Mr. Mateen Siddiqui, Advocate; Counsel for State/Respondent: Mr. Shaleen Singh Baghel, Government Advocate.
