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Intentional Collision Constitutes Murder Under : Upholds Conviction in
The has delivered a landmark judgment in the case involving the death of Additional District and Sessions Judge Uttam Anand, upholding the of the two convicts found responsible for his murder. The Division Bench, led by Justice Rongon Mukhopadhyay and Justice Pradeep Kumar Srivastava, condemned the incident as an "" and an "audacious execution" that threatened the systemic integrity of the judicial process.
Case Background and Judicial Scrutiny On , Judge Uttam Anand was struck by an auto-rickshaw while on a customary morning walk near Randhir Verma Chowk in Dhanbad. The collision, lasting roughly one second, resulted in fatal head injuries. Initially treated as a , the case gained national attention due to CCTV footage that appeared to show the vehicle explicitly veering towards the judge.
Following a demand for an impartial probe, the investigation was transferred from the local to the . The subsequent trial resulted in the conviction of Lakhan Kumar Verma and Rahul Kumar Verma under and 201/34 of the . The convicts challenged this sentence in the , questioning the absence of motive and the reliance of the prosecution on .
Arguments and Forensic Evidence The defense counsel argued that there was no "" or pre-existing enmity between the appellants and the judge, maintaining that the collision was an accident compounded by the presence of a roadside stone. Conversely, the prosecution, led by Senior Counsel , produced a mountain of —including , , and from entities like and the . Experts testified that the driver had full control of the vehicle and had swerved at an intentional 21-degree angle, dismissing the claim of mechanical failure or random accident.
Key Observations The ’s analysis emphasized the robustness of over traditional motive-based arguments. The judgment noted:
"The enormity of the act of the appellants and the audacious nature of its execution has been an encapsulating serious concerns over the safety and security of the judicial officers."
Regarding the application of Section 300 "Thirdly" IPC, the Court observed:
"Once the intention to cause the bodily injury actually found to be present is proved, the rest of the enquiry is purely objective and the only question is whether, as a matter of purely objective inference, the injury is sufficient in the ordinary course of nature to cause death."
On the issue of motive, the Bench stated:
"The argument of the defense that the prosecution has not been able to establish any motive on the accused for committing this dastardly act is in fact true, but since this is a case of eyewitness where there is nothing to discredit the eyewitness, the motive itself is of little relevance."
Final Decision and Judicial Implications The dismissed the appeal, ruling that the combination of , , and digital evidence created a "deluge" of proof regarding the intentional nature of the act. By upholding the life term, the Court has reinforced a stringent stance on physical assaults against judicial officers. This ruling sets a firm precedent for future criminal trials involving "" as a mode of murder, affirming that when direct evidence of the act is established, the lack of an overt, pre-existing motive does not impede a conviction for murder under .
