The oral version and the medical evidence were “irreconcilable,” and the latter must prevail, the Patna High Court has said, acquitting three men of a 2005 murder in Jamui and setting aside their life sentences.
Patna: The Patna High Court has set aside the conviction under Sections 302/34 of the Indian Penal Code and the life sentence of Satyanarayan Yadav, Gopal Yadav and Jhotaha Yadav for a 2005 murder in Jamui district, giving them the benefit of doubt after finding that the medical evidence could not be reconciled with the informant’s account of the weapon and the injury, and that the investigation left material gaps [Satyanarayan Yadav and Ors. v. State of Bihar].
A Division Bench of Justice Sanjay Kumar Singh and Justice Ansul, in a judgment authored by Justice Ansul, allowed the appeal filed in 2008 against the judgment of the Ist Additional Sessions Judge, Jamui, in Sessions Trial No. 47 of 2006.
The case
The case began with Sono P.S. Case No. 42 of 2005, lodged on the statement of the deceased’s brother, who is also the informant and a prosecution witness. He alleged that on May 14, 2005, around 11 AM, the three appellants, who were on inimical terms with his family over a land dispute, assaulted his brother with the butt of a “Tangi” and killed him. These are allegations of the prosecution, and the appellants were tried and convicted on them in December 2007. The trial court sentenced each to life imprisonment and a fine of Rs 2,000.
Of the twelve witnesses examined, PW-1 to PW-8 and PW-10 did not support the prosecution and were declared hostile, most saying they knew nothing of the occurrence. The post-mortem doctor recorded incised wounds on the forehead and the left cheek, among other injuries.
Medical evidence did not match the FIR
Relying on the Supreme Court’s decisions in Ram Narain Singh and Khambam Raja Reddy, the Bench held that where ocular testimony cannot be related to the injuries found, the court may decline to accept it. The FIR identified the neck as the part of the body attacked and the blunt side of the Tangi as the weapon. The Court observed:
“Neither incised wound corresponds to the neck, the part of the body the FIR identifies, and the weapon named, the blunt side of the Tangi, could not in any event have produced an incised wound at all.”
It concluded:
“The oral version and the medical evidence are, on this record, irreconcilable, and the medical evidence, being the more disinterested and forensically grounded of the two, must prevail.”
No weapon, no blood, no site plan
The Court noted that both the informant’s statement and his deposition named the weapons, the Tangi for one appellant and the lathi for the other two, yet neither was ever seized or exhibited. It added that the place of occurrence rested on nothing beyond the informant’s word, with no blood at the spot and no site plan, and that the land dispute papers, though sought, were not produced. Citing Abdul Wahid and Anr. v. State of Rajasthan (2025 INSC 295), the Bench held that these omissions “weigh cumulatively in favour of the accused,” and that the fardbeyan, the FIR and the inquest were not proved.
Acquittal on benefit of doubt
Holding that the investigation “suffers from lapses that benefit the accused rather than the prosecution,” the Bench found that the prosecution had not proved its case beyond reasonable doubt. The conviction dated December 24, 2007 and the sentence dated January 2, 2008 were set aside, and the three appellants, who were on bail, were discharged from their bail bonds.
Why The Patna High Court Judgment Matters
The ruling reiterates that a conviction cannot rest on an informant’s version that the medical evidence contradicts, and that unrecovered weapons, missing blood and the absence of a site plan can together create reasonable doubt in a case built on a single interested witness.
Case Title: Satyanarayan Yadav and Ors. v. State of Bihar [Criminal Appeal (DB) No. 45 of 2008]
Bench: Justice Sanjay Kumar Singh and Justice Ansul, Patna High Court
Date of Judgment: October 5, 2026
Appearances: Advocate Pankaj Kumar Sinha for the Appellants; APP S.C. Mishra for the State