News Citation : 2026 LN (HC) 116 | 2026:CGHC:5685-DB
February 02, 2026 : The High Court of Chhattisgarh has upheld the life sentences of three men convicted for the gang rape and murder of a woman in Balod district, ruling that DNA evidence, when properly collected and corroborated, is sufficient to sustain a conviction even in the absence of eyewitnesses.
A division bench headed by Chief Justice Ramesh Sinha dismissed two criminal appeals challenging a trial court verdict that had convicted Kamalnarayan Sahu, Kamlesh Kumar Shrivas, and Uttam Kumar Rawate for offences including house trespass, gang rape, murder, and criminal conspiracy. The trial court had sentenced the men to life imprisonment, directing that all sentences run concurrently.
The case dates back to June 12, 2021, when the victim was found dead inside her home in village Kosmi under Daundilohara police station limits. Family members discovered her body after she failed to respond in the morning. She was found lying face down on a cot, partially unclothed, with her hands tied behind her back. Medical examination later confirmed that she had been sexually assaulted and killed by asphyxiation caused by smothering.
During the investigation, forensic experts recovered semen from vaginal swabs and slides, as well as bloodstains from items seized at the scene, including a pillow. DNA analysis conducted by the State Forensic Science Laboratory in Raipur matched the biological samples with all three accused. The DNA profile of one of the accused was also found in the vaginal samples taken from the victim.
Before the High Court, the defence argued that the conviction rested entirely on circumstantial evidence and that the DNA samples were unreliable due to alleged violations of standard operating procedures. Counsel contended that the crime scene had not been properly secured, that the chain of custody was broken, and that the possibility of contamination could not be ruled out. They also pointed to the absence of eyewitnesses and the lack of blood or other physical traces belonging to the accused at the scene.
Rejecting these submissions, the court held that the prosecution had demonstrated due compliance with forensic guidelines for the collection, storage, and transportation of DNA samples. The bench noted that the biological exhibits were properly sealed, documented, and transmitted through an established chain of custody, and that no material evidence had been produced to show tampering or contamination.
The judges also relied on medical evidence confirming that the victim had been subjected to forcible sexual intercourse immediately before her death and that the cause of death was homicidal. The court observed that while the case was based on circumstantial evidence, the chain of circumstances was complete and pointed unerringly to the guilt of the accused.
Citing recent rulings of the Supreme Court of India, the High Court reiterated that DNA evidence is a powerful and reliable tool when handled in accordance with law, and that the absence of eyewitness testimony does not weaken a case where scientific evidence conclusively links the accused to the crime.
Finding no perversity or legal infirmity in the trial court’s reasoning, the High Court affirmed the convictions and sentences. The appeals were dismissed, and the accused were directed to continue serving their life terms. The court also informed the appellants of their right to approach the Supreme Court with legal assistance if they wished to challenge the verdict further.
Case Reference : CRA No. 371 of 2024 (Kamalnarayan Sahu vs State of Chhattisgarh) along with CRA No. 670 of 2024 (Kamlesh Kumar Shrivas and another vs State of Chhattisgarh); counsel for the appellant in CRA 371/2024: Smt. Fouzia Mirza, Senior Advocate, assisted by Ms. Aditi Singhvi, Advocate; counsel for the appellant in CRA 670/2024: Mr. Ashok Kumar Swarnakar, Advocate; counsel for the respondent/State: Mr. S.S. Baghel, Government Advocate.
