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'' Seals Fate: Patna HC Upholds Life Terms in 8-Year-Old's Brutal Rape-Murder
In a stark affirmation of 's power, the dismissed appeals by Sanjay Bhagat and Lala Miya @ Yasin, upholding their life imprisonment for the rape and murder of an 8-year-old Dalit girl from Muzaffarpur. A Division Bench of Honourable Mr. Justice Bibek Chaudhuri and Honourable Mr. Justice Ansul ruled on , that the men's failure to explain the child's death—after being seen abducting her—shifted the burden under , proving guilt beyond doubt.
A Village Shattered: The Night of Abduction
On , around 10 PM in Mustafapur village under Ahiyapur police station, Ashok Ram (the victim's father) was asleep after dinner when Sanjay Bhagat and Lala Miya forced entry into his home. They dragged out his daughter, Renu Kumari @ Bhutia, muffling her cries and carrying her on a shoulder, as eyewitnesses later testified. The family raised alarms, searched with villagers—even checking the accused's homes—but found nothing that night.
By morning, locals discovered the girl's body in a nearby litchi orchard owned by Jamruddin Miyan. Ashok Ram identified her, alleging the duo—known to the family—raped and killed her due to her Mahadalit background. An FIR (No. 99/2017) followed his , leading to trial in Sessions Trial No. 21/2017 before the . The trial court convicted them on , under , plus , sentencing life terms with fines, half payable to the family.
Defense's Desperate Plea Falls Flat
The appellants, represented by senior counsel , argued the prosecution story was improbable: How could they snatch a child sleeping beside her mother without resistance, evade a chase, yet no one caught them? They claimed witnesses improved statements from the FIR, lacked cross-examination on contradictions, and suggested a prior litchi business dispute as motive—though never put to prosecution witnesses. No alibi or alternative explanation emerged; they baldly denied involvement under .
Prosecution, via APPs and informant counsel, leaned on eyewitnesses: neighbor Parwati Devi (PW-1) saw Lala carrying the girl with Sanjay; mother Sunita Devi (PW-6) and father Ashok (PW-7) corroborated; maternal uncle Sone Lal Ram (PW-2) spotted them in torchlight. Post-mortem by Dr. Vijay Kumar (PW-8) confirmed strangulation asphyxia, vaginal laceration, ruptured hymen—death within 12-24 hours. IO Ravindra Kumar (PW-9) supported recovery. Defense witnesses offered weak alibis and unsubstantiated disputes.
: A Tight 10-Hour Window
The High Court dissected the "
" principle, invoking Section 106
's
for facts in the accused's special knowledge. With sightings around 10 PM and body recovery ~10 hours later at night—no other suspects, no alternative theory—the gap was
"so small that possibility of any person other than the accused being the author of the crime becomes impossible."
The bench critiqued defense lapses: no effective cross-examination, no alibi witnesses, denial without explanation. Trial court was chided for not invoking for clarity, but the record—sans case diary contradictions—stood firm.
Drawing from Supreme Court precedents like Chetan v. State of Karnataka (2025) 9 SCC 31, which clarified short gaps rule out third-party involvement; State of Rajasthan v. Kashi Ram (2006) 12 SCC 254, stressing explanation duty; and others ( , ), the court held: failure to explain completed the .
"The last seen, time lag and absence of any other theory or explanation for the killing of the deceased unerringly point towards the guilt of the accused persons and nothing else."(Para 29)
Court's Unyielding Verdict
"We do not find a case for interference as the prosecution has proved its case . Hence, there is no infirmity in the impugned judgment... this appeal stands dismissed."(Para 33-34)
Life sentences run concurrently; fines remain. This ruling reinforces "last seen" in child atrocity cases, especially with medical corroboration and no defense rebuttal—echoing media reports on the bench's focus on the 10-hour gap shifting burden. For future trials, it signals courts must probe silences in circumstantial webs, safeguarding vulnerable victims while demanding accused accountability.
"Once the factum of last seen is established, would come into play... In absence thereof... the accused must provide at least a minimum explanation."(Para 24)
A grim reminder: in the shadows of a village night, justice traced an unbreakable evidentiary thread.
