Patna High Court Overturns Murder Conviction Under Sections 302/34 IPC Citing Wholly Unreliable Witness Testimony

A Fatal Dispute Over an Eave: Patna High Court Acquits Accused in 1994 Murder Case

In a significant judgment delivered on April 9, 2026, a Division Bench of the High Court of Judicature at Patna acquitted Gaya Manjhi of murder charges, bringing an end to a legal battle that originated over three decades ago. The court’s decision to set aside the conviction of the 1st Additional Sessions Judge, Nawada, centered on the profound unreliability of the prosecution's star witnesses and the procedural frailty of the investigative process.

The Backdrop: A Village Skirmish Turns Fatal

The case dates back to July 15, 1994, in the district of Nawada. The prosecution alleged that a dispute over the construction of an olti (an eave or drainage structural element) between the deceased, Kameshwar Manjhi, and the accused, Mahabir Manjhi and Gaya Manjhi, escalated into a violent altercation. It was claimed that the accused returned armed with a sword and a garasa , resulting in the fatal wounding of Kameshwar Manjhi. While Mahabir Manjhi passed away in custody in 2001, the appeal filed by Gaya Manjhi continued to navigate the corridors of the judicial system for over 25 years.

Arguments: A Case Built on Flimsy Foundations

On behalf of the appellant (Gaya Manjhi), the defense argued that the prosecution’s case was riddled with inconsistencies. The primary contention was that the two central witnesses—the deceased’s wife (Janki Devi, PW-3) and son (Bhola Manjhi, PW-4)—provided contradictory accounts of their presence at the scene. Furthermore, the defense pointed to suspicious elements, including potential interpolation in the FIR and an unexplained delay in its transmission to the court, reinforcing the argument that the case was ante-dated and engineered.

Conversely, the State argued that the gruesomeness of the injuries, confirmed by the post-mortem report, supported the prosecution’s narrative. The state suggested that minor clerical errors in the FIR should not overshadow the substantive evidence of the crime.

Judicial Reasoning: Doubt Prevails

The Patna High Court meticulously dismantled the prosecution's reliance on PW-3 and PW-4. The bench noted that Janki Devi claimed to be the sole witness to the occurrence, effectively excluding the presence of anyone else—including her own son, the informant. This stood in direct contrast to the son's testimony, who also claimed to be an eyewitness but presented a differing sequence of events.

Citing the precedent set by the Supreme Court in Kannaiya v. State of Madhya Pradesh (2025), the bench reaffirmed that when the genesis and manner of an incident are riddled with doubt, a conviction cannot be upheld.

Key Observations

The High Court’s ruling highlighted fundamental failures in the evidentiary chain:

• "Both these witnesses have given contradictory versions regarding their being an eyewitness and presence at the place of occurrence and therefore, conviction cannot be upheld relying upon these witnesses."
• "In view of the complete denial of having seen the occurrence and also the fact as to who had assaulted... the entire case of the prosecution... becomes doubtful."
• "As per her deposition, she [Janki Devi] has stated that Mahabir Manjhi assaulted Kameshwar Manjhi... by 'saif' while Gaya Manjhi, the appellant no. 2, assaulted with garasa... during her cross-examination, P.W.-3 has stated that during the altercation apart from the accused persons, it was only her who was present at the time of occurrence."
• "It is a well-settled principle of law that when the genesis and the manner of the incident is doubtful, the accused cannot be convicted."

Final Decision: The End of a Long-Standing Legal Saga

Finding the evidence insufficient to maintain the charge beyond a reasonable doubt, the High Court allowed the appeal and set aside the lower court’s order of conviction and sentence. Gaya Manjhi was acquitted, marking the conclusion of a case that underscored the necessity of robust, consistent, and credible witness testimony in securing life-altering criminal judgments. The court ordered the discharge of the appellant's bail bonds, provided he submits valid surety for any further proceedings, signaling a total legal victory for the appellant.