High Court of Chhattisgarh Acquits Four in 2014 Rajnandgaon Murder Case, Says FIR Alone Not Enough for Conviction

News Citation : 2026 LN (HC) 136 | 2026:CGHC:2705-DB

January 16, 2026 : In a significant ruling, the High Court of Chhattisgarh at Bilaspur has set aside the life sentences of four men convicted in a 2014 murder case from Rajnandgaon district, holding that a First Information Report cannot by itself form the basis of conviction without substantive supporting evidence.

The Division Bench of Justice Sanjay K. Agrawal and Justice Arvind Kumar Verma delivered the judgment on January 16, 2026, allowing three connected criminal appeals arising out of a common trial court verdict dated November 28, 2015. The case stemmed from Sessions Trial No. 24 of 2014, in which the Additional Sessions Judge, Khairagarh, had convicted the accused under Section 302 read with Section 34 of the IPC and sentenced them to life imprisonment with a fine of Rs. 1,000.

The appeals were filed by Baital Sahu, Krishna Yadav alias Chhotu, Vinod Yadav and Manish Singh Rajput, who were all on bail during the pendency of the proceedings.

According to the prosecution, on the night of June 29, 2014, near Banjari Mandir in Pendrikala village under Khairagarh police station, the accused allegedly assaulted Prakash Sahu and Kanwar Devar with wooden sticks and iron rods. Prakash Sahu later died due to injuries, while Kanwar Devar survived.

A post-mortem examination concluded that the cause of death was shock and hemorrhage resulting from ante-mortem liver injuries. The trial court had relied on this medical evidence along with the FIR and recovery of alleged weapons and blood-stained clothes to convict the accused.

However, the High Court found serious gaps in the prosecution’s case.

The prosecution’s case largely depended on Kanwar Devar, the injured eyewitness and informant. But during trial, he turned hostile. He told the court that due to darkness he could not identify the assailants and claimed he had been struck by a vehicle and lost consciousness. He also stated that he had not named any accused in his police report.

The High Court noted that an FIR is not a substantive piece of evidence. It can only be used to corroborate or contradict the maker under the Evidence Act. Since the informant did not support the contents of the FIR in court, the document could not independently sustain a conviction.

Citing multiple Supreme Court precedents, the Bench reiterated that allegations in an FIR must be proved through reliable oral and documentary evidence. In this case, that standard was not met.

The prosecution had also relied on the recovery of rods, a wooden stick and clothes allegedly stained with human blood. While forensic analysis confirmed the presence of human blood, there was no evidence linking the blood to the deceased. The blood group was not matched.

The court also noted a two-month delay between seizure of the articles and their dispatch to the Forensic Science Laboratory, with no clear proof that the items were kept in safe custody during that period. This raised the possibility of tampering.

Relying on Supreme Court rulings, the Bench held that mere recovery of blood-stained articles, without corroborative evidence, cannot form the sole basis for conviction.

After examining the record, the High Court concluded that the prosecution had failed to prove the case beyond reasonable doubt. It found that the trial court had committed a legal error by placing undue reliance on the FIR and inquest report.

As a result, the conviction and life sentence under Section 302/34 IPC were set aside. The appellants were acquitted on the benefit of doubt. Since they were already on bail, they were not required to surrender, though their bail bonds will remain in force for six months under Section 437A of the CrPC.

Case Reference : Criminal Appeal No. 1525 of 2015 (Krishna Yadav @ Chhotu and Another vs State of Chhattisgarh), Criminal Appeal No. 1598 of 2015 (Baital Sahu vs State of Chhattisgarh) and Criminal Appeal No. 1630 of 2015 (Manish Singh Rajput vs State of Chhattisgarh); for the appellants: Mr. H.S. Ahluwalia, Advocate; Mr. Siddharth Pandey, Advocate; and Mr. Maneesh Sharma, Advocate; for the respondent-State: Mr. Sharad Mishra, Panel Lawyer.