Patna High Court Upholds Acquittal Due to Lack of Medical Evidence and Witness Contradictions

Simplified Explanation of the Judgment

In this case, the Patna High Court dealt with a criminal appeal challenging the acquittal of three individuals (referred to as Respondent Nos. 2 to 4) by the Sessions Court in Bhojpur. The case arose from a violent village altercation that took place in 1997, initially sparked by a dispute over plucking mangoes.

According to the First Information Report (FIR), a scuffle broke out involving several individuals. During the fight, a group of men allegedly attacked members of the informant’s family with sticks and bricks. Some of the injured were women and elderly individuals. Among the injured was a man who later died from his injuries. As per the FIR, the women accused (Respondent Nos. 2 to 4) had thrown bricks from the rooftop, causing further injuries.

The trial, which spanned decades due to various delays and the demise of some accused, ultimately led to the acquittal of the three respondents. The trial court found inconsistencies in the witness statements and a complete lack of medical evidence, including no postmortem report or injury report. Importantly, the investigating officer (IO) did not appear for full cross-examination, weakening the prosecution’s case.

On appeal, the High Court affirmed the acquittal, emphasizing key legal principles. Firstly, it noted that when two views are possible from the evidence, and the trial court has taken one, the appellate court should not interfere unless the view is perverse. In this case, the prosecution’s failure to bring in medical evidence, contradictory witness testimonies, and the possibility of false implication due to land disputes meant the trial court’s view was reasonable.

The High Court highlighted that only a medical expert can confirm whether the alleged injuries caused death. Since no doctor testified, and the postmortem report was not on record, it was impossible to establish that the respondents caused the fatal injuries. Given this, the acquittal was upheld.

Significance or Implication of the Judgment

This judgment underlines the importance of thorough investigation and consistent evidence in criminal trials, especially when it comes to serious charges like murder. It highlights the legal requirement that prosecution must prove its case beyond reasonable doubt, using both oral and documentary evidence, especially medical testimony in cases of alleged homicide.

For the general public and law enforcement, it is a reminder that accusations must be backed by credible and corroborative proof. For courts, it reinforces the principle that in appeals against acquittal, interference is limited to instances where the trial court’s decision is irrational or unsupported by facts.

Legal Issue(s) Decided and the Court’s Decision

  • Whether the prosecution proved that Respondent Nos. 2 to 4 caused the death of the victim?
    • Decision: No. The prosecution failed to produce medical evidence and witnesses were inconsistent.
  • Was the acquittal by the trial court valid in law?
    • Decision: Yes. The view of the trial court was reasonable, and no illegality was found in the acquittal.

Judgments Relied Upon or Cited by Court

  • Harbans Singh v. State of Punjab, 1961 SCC OnLine SC 40
  • Chandrappa vs. State of Karnataka, (2007) 4 SCC 415
  • Murugesan vs. State, (2012) 10 SCC 383
  • H.D. Sundara vs. State of Karnataka, (2023) 9 SCC 581
  • Babu Sahebagouda Rudragoudar vs. State of Karnataka, 2024 SCC OnLine SC 561

Case Title
Brij Bihari Ray vs. The State of Bihar & Others

Case Number
Criminal Appeal (DB) No.108 of 2021

Citation(s)– 2025 (1) PLJR 58

Coram and Names of Judges
Hon’ble Mr. Justice Rajeev Ranjan Prasad
Hon’ble Mr. Justice Jitendra Kumar

Names of Advocates and who they appeared for
Mr. Tej Pratap Singh — For the Appellant
Mr. A.G. — For the State
(Name not specified) — For Respondents Nos. 2 to 4

Link to Judgment
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