2026 Supreme(Online)(Chh) 16294

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ, Ravindra Kumar Agrawal, J
Vicky @ Sukhiram Yadav – Appellant
Versus
State of Chhattisgarh – Respondent
CRA No. 631 of 2023

In a case based on circumstantial evidence, the prosecution must establish a complete chain of circumstances pointing unerringly to the guilt of the accused, and an extra-judicial confession, if voluntary and truthful, can form the basis of conviction.

Headnote:(A) Indian Penal Code, 1860 - Sections 302, 201, and 304 - Code of Criminal Procedure, 1973 - Section 374(2) - Indian Evidence Act, 1872 - Sections 8, 27, and 105 - Conviction under Sections 302 (two counts) and 201 IPC - Appeal against conviction - Case based on circumstantial evidence - Principles for appreciation of circumstantial evidence laid down in Hanumant Govind Nargundkar v. State of M.P. and Sharad Birdhichand Sarda v. State of Maharashtra (Panchsheel) - Extra-judicial confession, if voluntary and truthful, can form basis of conviction - Recoveries under Section 27 of Evidence Act are admissible if they lead to discovery of facts exclusively within knowledge of accused - Motive, though not necessary where direct evidence exists, is an important link in circumstantial evidence - Plea of insanity under Section 84 IPC - Burden of proof on accused under Section 105 Evidence Act - Mere abnormality of mind or emotional disturbance does not attract Section 84 IPC - Appellate Court’s scope of interference is limited to perversity, illegality, or infirmity; findings of fact based on proper appreciation of evidence are not to be interfered with merely because another view is possible. (Paras 26, 39-41, 47, 66-68, 83-86, 95-100)

(B) Evidence - Appreciation - Circumstantial evidence - Each circumstance must be fully established and all circumstances must form a complete chain pointing only towards guilt of accused, excluding every hypothesis of innocence - Medical evidence, when consistent with prosecution story, provides strong assurance - FSL and DNA reports are vital corroborative evidence - Recovery of weapon and blood-stained clothes at instance of accused constitutes strong incriminating circumstance - Conduct of accused before and after incident under Section 8 of Evidence Act is relevant. (Paras 34, 39-41, 52-53, 57, 69-70)

Facts of the case:
The appellant was convicted for the murder of a woman by inflicting fatal knife injuries on her neck and for the murder of her minor daughter by smothering her and laying her on a railway track, where she was run over by a train. The prosecution case was based on motive (prior threats by the appellant to kill the deceased), an extra-judicial confession made by the appellant to a former Sarpanch, recoveries of a blood-stained knife and clothes pursuant to a memorandum statement under Section 27 of the Evidence Act, medical evidence establishing homicidal death, FSL report confirming human blood on the seized articles, and a DNA report establishing biological relationship between the appellant and the deceased. The appellant pleaded false implication and raised defences of sudden provocation, absence of intention, and insanity. The trial court convicted him under Sections 302 (two counts) and 201 IPC.

Findings of Court:
The court held that the prosecution established a complete chain of circumstantial evidence, including motive, extra-judicial confession, recoveries, medical evidence, FSL report, and DNA report, which pointed unerringly to the guilt of the appellant. The conviction was affirmed, and the sentence of life imprisonment under Section 302 IPC (two counts) and rigorous imprisonment under Section 201 IPC was upheld. The court found no perversity, illegality, or infirmity in the trial court’s judgment. The appellant’s pleas of false implication, sudden provocation, and insanity were rejected as unsubstantiated.

Issues: (i) Whether the deaths were homicidal in nature? (ii) Whether the chain of circumstantial evidence was complete and pointed unerringly to the guilt of the appellant? (iii) Whether the memorandum statement and consequent recoveries were duly proved? (iv) Whether the conviction suffered from perversity, illegality, or infirmity? (v) Whether the defence pleas of false implication, absence of intention, sudden provocation, or insanity were made out?

Ratio Decidendi: The court ruled that the prosecution had proved each incriminating circumstance beyond reasonable doubt, and the cumulative effect of all circumstances formed a complete chain excluding every hypothesis consistent with the appellant’s innocence. The extra-judicial confession was voluntary and truthful, corroborated by recoveries and scientific evidence. The recoveries under Section 27 of the Evidence Act were admissible and constituted a vital link. The appellant failed to discharge the burden of proving the defence of insanity under Section 84 IPC. The trial court’s findings were based on proper appreciation of evidence and were not perverse. Result : Appeal dismissed. Conviction and sentence affirmed.