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SUPREME COURT OF INDIA
PRASHANT KUMAR MISHRA, VIPUL M. PANCHOLI, JJ.
Gautam Satnami – Appellant
Versus
State of Chhattisgarh – Respondent
Criminal Appeal No. 1782 of 2026 [Arising Out of S.L.P. (Criminal) No. 11080 of 2022]
Decided On : 07-04-2026
(A) Constitution of India – Articles 134 and 136 – Appellate Jurisdiction – Under Article 134, Supreme Court sits as a regular Court of appeal, but under Article 136, ordinarily limits itself to correcting manifest illegality and/or grave miscarriage of justice – However, any restrictions are not absolute – Both provisions underline that Supreme Court has final, Constitutional responsibility to ensure that justice is done – Nature and scope of Court’s powers under Article 136 are not curtailed where interests of justice so require. (Paras 12 and 13)
(B) Indian Penal Code, 1860 – Section 302 – Murder – Life imprisonment – Circumstantial evidence – Motive is a supporting factor which strengthens an otherwise complete chain of evidence – It cannot replace such a chain where other circumstances are missing or weak Witnesses have either turned hostile or not corroborated case of prosecution on any material particulars in relation to recoveries beyond just admitting their signatures – Recovery circumstance remains legally tenuous – Remaining distinguishing circumstances relied upon by appellant are also weak and inconclusive – – Prosecution’s case fails at threshold itself, as each circumstance from which guilt is to be inferred is not firmly and fully established – Evidence on record may raise suspicion, but, suspicion, however strong, cannot take place of proof – Appellant acquitted – Appeal allowed. (Paras 25, 26, 30, 31 and 32)
Facts of the case:
Instant Appeal takes exception to judgment dated 19.07.2017 passed by High Court of Chhattisgarh at Bilaspur in Criminal Appeal No. 677 of 2012, whereby judgment and order dated 28.07.2012 passed by Sessions Judge, Rajnandgaon in Sessions Case No. 27 of 2011 was affirmed. Trial Court had convicted sole appellant under Section 302 of Indian Penal Code, 1860 and sentenced him to undergo life imprisonment with a fine of Rs. 5,000 and in case of default in payment of fine to undergo additional rigorous imprisonment for one year.
Findings of Court:
It cannot even be said with certainty that the driving licence was recovered from the spot in the manner alleged, let alone that its presence there was consistent only with the hypothesis of guilt. Evidence on record may raise suspicion, but, suspicion, however strong, cannot take place of proof. Appellant, like accused No. 2, deserves benefit of doubt.
Result : Appeal allowed.
| Table of Content |
|---|
| 1. factual background of the murder case. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9) |
| 2. arguments from both parties regarding the conviction. (Para 10 , 11) |
| 3. the court's analysis on appeal jurisdiction and findings. (Para 12 , 13 , 14) |
| 4. evaluation of witness reliability and animosity context. (Para 15 , 16 , 17 , 18 , 19) |
| 5. examination of evidence sufficiency and confession admissibility. (Para 20 , 21 , 22 , 23) |
| 6. concerns on the strength and credibility of prosecution evidence. (Para 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31) |
| 7. final judgment and acquittal of the appellant. (Para 32) |
JUDGMENT :
PRASHANT KUMAR MISHRA, J.
1. Leave granted.
2. The instant Appeal takes exception to the judgment dated 19.07.2017 passed by the High Court of Chhattisgarh at Bilaspur in Criminal Appeal No. 677 of 2012, whereby the judgment and order dated 28.07.2012 passed by the Sessions Judge, Rajnandgaon in Sessions Case No. 27 of 2011 was affirmed. The Trial Court had convicted the sole appellant, Gautam Satnami @ Gautam Deshlahre, who was accused No. 1, under Section 302 of the Indian Penal Code, 18601 [For short “IPC”] and sentenced him to undergo life imprisonment with a fine of Rs. 5,000 and in case of default in payment of fine to undergo additional rigorous imprisonment for one year.
FACTUAL MATRIX
3. The deceased, Dhumman @ Surjeet Bhattacharya, resided alone in his house in village Dhourabhata and was engaged in the business of selling lentils on his motorbike (Luna). His fufa - Ghasi Ram (PW-16), was residing next to his house. The deceased was married for 4-5 times, including to one Dharmin Bai (PW-2), who had returned to her maternal home a few years before the incident due to disputes with the deceased.
4. In the evening of 13.01.2011, the deceased was consuming liquor in his house with Girish Satnami (PW-12) and Tejprakash Satnami. At about 7:00 p.m. Dhanraj (PW-3) overheard noises from the deceased’s house, and on stopping by, saw the appellant and Dwarika Jangde (accused No. 2 since acquitted) present over there. The appellant had a liquor bottle in his hand and was abusing the deceased, saying that because of him, the appellant had gone to jail, and that one day he would kill him. It is said that two years before the incident, the appellant and the deceased had fought with another villager, Tikam Sahu, and the deceased had secured bail for him while the appellant had to go to jail because he was absconding. This spawned an ongoing animosity in their friendship.
5. It is further the case of the prosecution that on the next day i.e.. 14.01.2011, the accused went to the deceased’s house at night and when the deceased opened the door, the accused, armed with axes, inflicted multiple incised injuries on him, resulting in instantaneous death on account of shock due to excessive haemorrhage. After committing the murder, the accused persons fled from the spot. One Raja Ram Deshlahare (PW-4), riding pillion, along with Maniram Sahu allegedly saw the appellant with an axe near the deceased’s house in the headlight of the motorcycle and he found the lights of the house were also turned on.
6. The deceased’s body was discovered the next day. One Hiraman (PW-1) saw next morning that the door of the deceased’s house ajar, blood on both the door and the floor, and the deceased’s corpse partially covered with a bedsheet. He suspected the appellant for the murder as the appellant had a criminal antecedent and was having enmity with the deceased for some time. Hiraman (PW-1) went and informed Ghasi Ram, and they visited the spot. Other villagers were also informed, after which merg intimation was lodged by the brother-in-law of the deceased namely, Komal Das (PW-8), against unknown persons. Thereafter, the dehati nalishi was registered on the same day around 2:00 p.m. wherein Komal Das stated that he saw half-open door of the deceased’s house, blood stains and hair on the door, and clothes and other articles scattered near the divan bed, as well as th
AI
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