Introduction
On 11th September 2024, the Patna High Court delivered its
judgment in Criminal Appeal (DB) Nos. 615, 591, 719, and 748 of 2019, in
the case of Shambhu Yadav & Ors. v. State of Bihar. The judgment
stemmed from a brutal daylight double murder in West Champaran in 2016,
emerging from a long-standing land dispute. This explanation breaks down the
court's reasoning, evidence, defense, and ultimate findings in a comprehensive
and accessible manner.
The Crime and Context
The incident occurred on 8th September 2016, around 5:15
PM, at Chhathia Ghat, West Champaran. Informant Mannan Yadav,
son of deceased Jhapas Yadav, narrated that while he, his father, and
his uncle Jhagru Yadav were sitting at a village platform, they were
suddenly surrounded by a group of armed men, including the six appellants and
others.
Dhruv Yadav, one of the key accused, reportedly
exhorted others to attack, alleging the victims were interfering in land
litigation. Immediately, he shot Mannan’s father, followed by a hail of bullets
and assaults with lathi, bhala, and farsa (traditional
weapons), leading to fatal injuries to both Jhapas and Jhagru. The victims were
rushed to a hospital but succumbed to their injuries. An FIR was lodged shortly
afterward.
Charges and Trial
The Sessions Court, after framing charges under
Sections 147, 148, 302 read with 149 IPC, and Section
27 of the Arms Act, found the accused guilty in 2019, sentencing
them to life imprisonment and varying terms for other charges. All
sentences were to run concurrently.
The accused then challenged their conviction in the High
Court, resulting in the appeals considered in the present judgment.
Prosecution’s Narrative and Evidence
The prosecution relied heavily on eyewitness testimonies,
medical reports, and seizure evidence:
- Eyewitnesses
(PW-1 to PW-6) – All testified seeing the armed group assaulting and
shooting the deceased. Though termed "chance witnesses," their
presence at or near the crime scene was consistently corroborated.
- Medical
Evidence (PW-7 & PW-8) – Confirmed grievous injuries, including gunshot
wounds, fractures, and sharp/blunt force trauma,
establishing the brutality and nature of weapons used.
- Investigating
Officer (PW-9) – His on-site findings, including blood stains,
cartridge seizures, and timely inquest and FIR, corroborated the crime's
sequence and authenticity of statements.
Defense Strategy: Denial and Alibi
The appellants denied involvement, pleading false
implication due to prior enmity, and put forth alibi witnesses
(DW-1 to DW-5) to establish that some accused were elsewhere during the
incident.
However, the High Court found these defense witnesses
unreliable due to inconsistencies, failure to recall basic facts (e.g.,
names, times, and events), and the lack of any such plea in Section 313 CrPC
statements. Importantly, the defense failed to establish that the accused were
so far away that their participation was impossible.
Court’s Observations and Legal Principles
The Patna High Court, speaking through Justice Jitendra
Kumar and concurred by Justice Ashutosh Kumar, undertook an
extensive review of:
- Eyewitness
credibility: The Court reiterated that related or chance witnesses
cannot be discredited solely due to their relation or presence. Their
testimony stood firm under cross-examination.
- Minor
inconsistencies: The Court held that minor contradictions,
natural in rustic village settings, enhanced credibility, proving
that the witnesses weren’t tutored.
- Medical-ocular
harmony: Injuries detailed in post-mortem reports matched eyewitness
accounts (gunshots, fractures, lathi and farsa blows), confirming coherence
between medical and verbal evidence.
- Plea
of alibi: Citing Binay Kumar Singh v. State of Bihar, the Court
emphasized that burden of proving alibi rests on the accused, which
wasn’t met satisfactorily. Even where defense witnesses supported the
alibi, their vague and inconsistent testimony failed to generate reasonable
doubt.
- Defective
investigation argument: The Court cited precedents asserting that defects
in investigation (if any) cannot override substantive evidence,
especially when eyewitness and medical evidence are strong.
Motive: A Powder Keg of Land Disputes
The judgment underscores that land disputes have long
festered between the parties, leading to multiple litigations and even prior
police cases. This provided a strong motive, which aligned with the
threats made by the accused before the murder and the sequence of the assault.
Key Judicial Precedents Relied Upon
The judgment is fortified with references to over a dozen
Supreme Court cases including:
- Ravi
Mandal v. State of Uttarakhand – On reliability of chance witnesses.
- Yogesh
Singh v. Mahabeer Singh – On credibility of related witnesses.
- C.
Muniappan v. State of T.N. – On minor inconsistencies not affecting
core truth.
- Pulicherla
Nagaraju v. State of A.P. – On evidentiary value of post-mortem
reports.
Final Verdict: Conviction Upheld
After evaluating all facets of the case, the High Court dismissed
all appeals and upheld the conviction and sentence awarded by the
trial court.
Key conclusions included:
- The
prosecution proved its case beyond reasonable doubt.
- Witness
testimonies were credible and consistent.
- The medical
evidence reinforced the manner and cause of death.
- The motive
was strong, and the defense failed to establish an alibi.
- There
was no illegality or infirmity in the trial court’s findings.
Conclusion: Justice Anchored in Law and Evidence
This judgment exemplifies the rigorous application of legal
principles, blending judicial prudence with the ground realities
of rural India. The High Court's refusal to be swayed by minor technicalities
or defensive distractions reflects a commitment to justice anchored in truth,
evidence, and judicial precedent.
In the end, Shambhu Yadav & Ors. v. State of Bihar
is not just about two tragic deaths. It is a grim tale of how long-standing
land disputes, fuelled by personal vendettas, can culminate in fatal
violence. The court's role in cutting through noise and delivering clarity is a
reminder of the power and duty of the judiciary to uphold the rule of law.
Read the full judgement Below;
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