The Patna High Court has allowed a criminal revision and overturned an appellate judgment that had convicted the petitioner for simple and grievous hurt and intentional insult under Sections 323, 325 and 504 of the Indian Penal Code. In doing so, the Court restored the trial court’s earlier acquittal, emphasizing that a conviction cannot rest on evidence that is either inconsistent, unsupported by independent witnesses, or medically uncorroborated. The Court noted multiple infirmities in the prosecution’s case, including the absence of supporting eyewitness testimony and a medical opinion on “grievous” injury that lacked foundational radiological proof.

In this matter, the dispute arose from an incident said to have occurred in the morning when the complainant was returning from a school and allegedly encountered the accused near a road junction. The prosecution case was that due to prior enmity, abuses were hurled, and the complainant’s left hand was grabbed, resulting in injury. The police registered an FIR for multiple offenses including wrongful restraint, hurt, grievous hurt, and insult, and after investigation, a charge-sheet followed. At trial, eight witnesses were examined for the prosecution. However, save for the complainant, other witnesses did not support the prosecution version. On that basis, the trial court acquitted all accused.

The complainant then preferred a criminal appeal. The appellate court reversed the acquittal as against the present petitioner alone, convicting him under Sections 323, 325 and 504 IPC. Interestingly, the same appellate court affirmed the acquittal of the other co-accused on the very same evidentiary record. While sentencing, the appellate court extended the benefit of probation for two years with reference to Sections 360 and 361 of the Code of Criminal Procedure and the Probation of Offenders Act, 1958. The petitioner challenged this reversal in revision before the Patna High Court.

Allowing the criminal revision, the High Court carefully examined the depositions and reasoning of both the trial and appellate courts. First, it observed that the complainant’s testimony stood alone: no independent witness supported the occurrence in the manner alleged. Notably, one named eyewitness (a local functionary who, according to the complainant, was present and had seen the incident) did not support the prosecution. This substantially weakened the prosecution story because the presence and observation of this witness were projected as central to corroboration but ultimately failed in court.

Second, the High Court evaluated the medical evidence. The examining doctor opined that the injury was “grievous,” yet conceded in cross-examination that no X-ray report was either seen or procured from a radiologist. In cases of alleged fracture or grievous hurt, courts generally look for objective medical corroboration such as radiological reports. In the absence of any X-ray findings or radiologist’s confirmation, the opinion on grievousness lacked a reliable foundation. The Court therefore found the medical characterization of the injury unacceptable.

Third, the High Court underscored an internal inconsistency in the complainant’s testimony. In cross-examination, the complainant admitted that, at the crucial moment, he was held from behind by the petitioner and another person and could not see them. This admission cast doubt on the identification and attribution of acts specifically to the petitioner. The appellate court, however, did not address this crucial nuance while convicting the petitioner alone, despite affirming the co-accused’s acquittal on the same record. The High Court regarded this as a serious flaw.

Fourth, the Court addressed the broader principle governing reversal of acquittal. While an appellate court has the power to reassess evidence, it must do so by engaging with the trial court’s reasons, and should not convict on evidence that it simultaneously finds unreliable for co-accused. Here, the appellate court rejected the complainant’s testimony regarding the others yet relied on it to convict the petitioner without addressing why the same testimony should be treated as trustworthy against one accused but untrustworthy against the others. This inconsistent approach, the High Court held, rendered the appellate finding “perverse” and contrary to the evidence on record.

On these cumulative grounds, the High Court set aside the appellate conviction and restored the petitioner’s acquittal. The revision was accordingly allowed. The ruling reiterates that criminal convictions must rest on coherent, corroborated evidence, and where the prosecution’s story is weakened by non-supporting witnesses, infirm medical opinion, and contradictions touching identification, benefit of doubt must go to the accused.

Significance or Implication of the Judgment

This decision has practical implications for criminal trials and appeals in Bihar:

• It reinforces the standard that a sole, uncorroborated witness—especially when contradicted by named eyewitnesses—may be insufficient for conviction, unless that testimony is of sterling quality and free from contradictions.
• It emphasizes the role of medical corroboration in establishing “grievous hurt.” Courts require objective proof (like X-ray confirmation) before accepting grievousness.
• It cautions appellate courts against selective reliance on the same testimony to acquit some co-accused and convict another without cogent reasoning; consistency in evidentiary assessment is essential.
• For the public, the judgment illustrates why due process sometimes leads to acquittal: criminal law prefers to err on the side of liberty when evidence is uncertain or internally inconsistent.
• For investigating agencies, it is a reminder to secure independent eyewitness support and complete medical documentation early to withstand judicial scrutiny.

Legal Issue(s) Decided and the Court’s Decision with reasoning

• Whether the appellate court was justified in reversing an acquittal and convicting the petitioner on the same evidentiary record that was found unreliable for co-accused.
  • Court’s Decision: No. The High Court held the appellate finding to be perverse because it selectively accepted the complainant’s testimony against one accused while rejecting it against others, without adequate reasoning.
• Whether the prosecution established “grievous hurt” under Section 325 IPC without radiological or equivalent objective proof.
  • Court’s Decision: No. The medical opinion lacked X-ray corroboration or a radiologist’s report, undermining the finding of grievousness.
• Whether conviction can rest primarily on the complainant’s testimony when named eyewitnesses do not support the occurrence and when the complainant admits he could not properly see the assailants at the crucial moment.
  • Court’s Decision: No. In the absence of reliable independent corroboration and in light of admissions affecting identification, conviction was unsafe; benefit of doubt must go to the accused.

Case Title
Ranbir Yadav @ Ranvir Kumar vs. State of Bihar

Case Number
Criminal Revision No. 143 of 2023 (arising out of Makhdumpur P.S. Case No. 139 of 2013; G.R. No. 1061 of 2013; Trial No. 767 of 2017)

Citation(s)
2025 (1) PLJR 302

Coram and Names of Judges
Hon’ble Mr. Justice Arvind Singh Chandel

Names of Advocates and who they appeared for

• For the petitioner: Mr. Vijay Kumar, Advocate; Mr. Kuber Pathak, Advocate; Mr. Devendra Kumar, Advocate
• For the State: Mr. Syed Mojibur Rahman, APP

Link to Judgment
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