Bilaspur Boy Kidnapping Case: Chhattisgarh HC Affirms Life Imprisonment for Accused.

News Citation : 2026 LN (HC) 347 | 2026:CGHC:23104-DB

May 15, 2026 : The High Court of Chhattisgarh has upheld the conviction and life sentence awarded to five persons in the sensational 2019 kidnapping-for-ransom case involving minor child Virat Saraf from Bilaspur, holding that the prosecution successfully established a “complete and unbroken chain of circumstances” proving the criminal conspiracy behind the abduction.

A Division Bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal dismissed multiple criminal appeals filed by Nita Saraf, Rajkishore Singh, Anil Singh, Satish Sharma and Harekrishna Kumar against their conviction by the First Additional Sessions Judge, Bilaspur in Sessions Case No. 113 of 2019. The High Court delivered the judgment on May 15, 2026, after reserving orders on April 21, 2026.

The case arose from Crime No. 145 of 2019 registered at City Kotwali Police Station, Bilaspur under Sections 363, 365, 368, 364-A, 120-B and 34 of the Indian Penal Code. The trial court had sentenced all the accused to life imprisonment under Section 364-A read with Section 120-B IPC and awarded additional sentences for conspiracy, kidnapping and wrongful confinement, with all punishments directed to run concurrently.

According to the prosecution, the conspiracy was masterminded by Nita Saraf, who was closely related to the victim’s family and had detailed knowledge of their personal affairs. The court noted that she and co-accused Anil Singh allegedly faced financial liabilities and initially planned to kidnap another relative’s child for ransom. However, after that family travelled out of town, the conspirators shifted their target to minor Virat Saraf.

The prosecution alleged that the accused carried out reconnaissance of the victim’s locality before executing the kidnapping on April 20, 2019. The child was allegedly abducted while playing near his residence and was transported first in a Wagon-R car and later shifted to a Duster vehicle before being confined in a room at Rajkishore Singh’s house in Panna Nagar, Jarhabhata, Bilaspur. Investigators claimed the accused tied the victim’s hands and legs and recorded his voice for ransom purposes.

The court noted that ransom calls demanding Rs 6 crore were subsequently made to the victim’s father, Vivek Saraf, from mobile numbers linked to SIM cards allegedly stolen from another person under false pretences. The investigation further revealed that the accused had purchased an old keypad phone and inserted the fraudulently obtained SIM cards into the device before making ransom calls from locations in Chhattisgarh and Uttar Pradesh.

The victim was ultimately rescued on April 26, 2019 during a police raid at Rajkishore Singh’s residence. Police recovered the child from a locked room allegedly occupied by Harekrishna Kumar and Satish Sharma. During the investigation, police seized multiple mobile phones, vehicles, CCTV footage, voice recordings, SIM cards, footwear belonging to the victim and other material evidence. Authorities also collected extensive electronic evidence including call detail records, tower locations, intercepted conversations, IMEI data and certificates under Section 65-B of the Indian Evidence Act.

The prosecution examined 54 witnesses and produced 191 documents during trial. The evidence included CCTV footage, fingerprint examination reports, voice sample analysis, mobile interception records and test identification parade proceedings.

Before the High Court, the defence challenged the conviction primarily on the ground that the case was based entirely on circumstantial evidence. Counsel for the accused argued that there were inconsistencies in the prosecution case, deficiencies in the test identification parade, and procedural irregularities in the collection of electronic evidence. It was further contended that mere call records between the accused could not establish criminal conspiracy.

The defence also argued that the essential ingredients of Section 364-A IPC dealing with kidnapping for ransom were not made out because there was allegedly no credible evidence of threats to the victim’s life or physical harm. Several accused further disputed the admissibility of memorandum statements and electronic records under Sections 25 and 26 of the Evidence Act and Section 65-B of the Evidence Act.

Opposing the appeals, the State argued that the conspiracy was established through a combination of circumstances including CCTV footage, mobile tower locations, recovery of the victim, ransom call transcripts, electronic surveillance and conduct of the accused before and after the kidnapping. The prosecution also emphasised that the accused had conducted “Reiki” of the victim’s locality and coordinated continuously through mobile phones while executing the abduction.

The High Court framed several core legal questions while examining the appeals, including whether the prosecution had proved the conspiracy beyond reasonable doubt, whether the electronic evidence was legally admissible, whether the chain of circumstances excluded every hypothesis of innocence and whether the trial court had committed any legal infirmity while recording conviction.

In its analysis, the Bench examined the evidentiary value of CCTV footage, digital evidence, fingerprint reports and ransom call records alongside the testimony of the victim and other prosecution witnesses. The court stressed that in cases based on circumstantial evidence, every circumstance must be firmly established and must point only toward the guilt of the accused. The Bench ultimately concluded that the prosecution had succeeded in establishing the conspiracy and execution of the kidnapping through corroborative scientific and oral evidence.

The judgment is significant because it reinforces the growing judicial reliance on digital and forensic evidence in organised kidnapping and ransom cases. The court’s discussion on admissibility of electronic records under Section 65-B of the Evidence Act also carries broader implications for future criminal prosecutions involving mobile surveillance, CCTV footage and digital communication records.

The ruling additionally highlights the seriousness with which Indian courts continue to treat offences under Section 364-A IPC, a provision introduced to combat kidnapping for ransom and organised criminal activity. The provision carries stringent punishment, including life imprisonment and even death penalty in aggravated cases.

The decision is likely to strengthen investigative reliance on cyber forensics and electronic surveillance in serious criminal prosecutions, particularly where direct eyewitness evidence is limited. It also serves as a reminder that conspiracy charges under Section 120-B IPC can be established through coordinated conduct, communications and surrounding circumstances even in the absence of direct proof of agreement between accused persons.

Case Reference : Nita Saraf v. State of Chhattisgarh (CRA No. 1555/2022) through Mr. Sourabh Dangi, Advocate; Rajkishor v. State of Chhattisgarh (CRA No. 1798/2022) through Mr. Rishi Rahul Soni, Advocate; Anil Singh v. State of Chhattisgarh (CRA No. 1823/2022) through Mr. Arvind Shrivastava, Advocate; Satish Sharma v. State of Chhattisgarh (CRA No. 2018/2022) through Mr. Vinod Kumar Sharma and Mr. Chandra Kumar, Advocates; and Harekrishna Kumar v. State of Chhattisgarh (CRA No. 218/2023) through Mr. Aakash Singh, Advocate; Ms. Vaishali Mahilong, Deputy Government Advocate appeared for the State in all matters.