In a significant judgment dated 4 January 2019, the Patna High Court upheld the life sentences of four individuals convicted in a 2010 murder case arising from a brutal assault at a public fair in Jehanabad district. The appeals filed by the convicts were dismissed, confirming the trial court’s verdict that found them guilty of participating in a premeditated and violent mob attack.
Simplified Explanation of the Judgment
This case stemmed from an incident on April 2, 2010, when the deceased, along with his brother (the informant), visited a fair (Meena Bazaar) at Gandhi Maidan in Jehanabad. An explosion and ensuing chaos occurred, prompting them to leave the fair. At that point, a group of about 30 to 35 individuals—allegedly hired by the fair’s management—attacked the victim with iron rods, sticks, and other weapons.
The victim sustained severe head injuries and was immediately rushed to Jehanabad Sadar Hospital. Due to his critical condition, he was referred to Rajeshwar Hospital in Patna, where he remained in the ICU until his death on April 9, 2010. His brother’s statement formed the basis of the FIR, which was initially delayed due to the victim’s medical emergency.
The trial court convicted four individuals—Raj Kumar Yadav, Teeju Yadav, Munna Yadav, and Satyanarayan Prasad—under various sections of the Indian Penal Code, including Section 302 (murder), read with Section 149 (unlawful assembly). Each was sentenced to life imprisonment and fined ₹10,000.
In their appeal before the High Court, the convicts questioned the delay in filing the FIR and in recording witness statements, and they also argued discrepancies between the medical and ocular evidence. However, the Court found the evidence presented by the prosecution—including eyewitness testimony and medical reports—reliable and consistent. The Court also dismissed the claim that the attack was spontaneous, noting prior tension and the accused’s targeted assault as indicators of premeditation.
The High Court concluded that the trial court’s findings were sound and that the prosecution had proven its case beyond reasonable doubt. Consequently, all four appeals were dismissed, and two of the appellants who were on bail were ordered to surrender.
Significance or Implication of the Judgment
This judgment reinforces the judiciary’s commitment to delivering justice in cases of organized violence. It clarifies that even if there is a delay in reporting due to medical emergencies or logistical issues, such delays do not automatically discredit the prosecution’s case—especially when there is corroborating medical and eyewitness evidence.
For the public, this decision serves as a warning against mob behavior and underscores the criminal liability of individuals who act in concert with a common unlawful purpose. It also reassures victims and their families that justice can prevail even in complex and delayed proceedings.
For the government and law enforcement, the ruling stresses the importance of prompt and transparent investigation, but also recognizes the ground realities in high-pressure cases.
Legal Issue(s) Decided and the Court’s Decision
- Whether the delay in filing FIR and recording statements invalidated the prosecution case:
➤ No. The Court found valid explanations for the delays and held that the evidence remained trustworthy. - Whether the assault was premeditated or a spontaneous act:
➤ The Court ruled it was premeditated, given prior altercations and targeted attack. - Whether Section 302 IPC (murder) applied or whether it should be downgraded to Section 304 Part II (culpable homicide not amounting to murder):
➤ The Court held that the assault with fatal intent supported a conviction under Section 302 IPC. - Whether medical evidence supported the ocular testimony:
➤ Yes. The injuries described by doctors matched the eyewitness accounts.
Case Title
Raj Kumar Yadav & Ors. vs The State of Bihar
Case Number
Criminal Appeal (DB) No. 651 of 2013
(Heard along with Criminal Appeals No. 585, 725, and 811 of 2013)
Citation(s)
2020 (1) PLJR 729
Coram and Names of Judges
Hon’ble Mr. Justice Rakesh Kumar
Hon’ble Mr. Justice Prakash Chandra Jaiswal
Names of Advocates and Who They Appeared For
- For the Appellants:
Mr. Vikramdeo Singh, Mr. Ashok Kumar Sinha, Mrs. Meena Singh, Mr. Paras Nath - For the State:
Mr. Ajay Mishra, Mr. S. N. Prasad - For the Informant:
Mr. Ramakant Sharma (Senior Advocate), Dr. Amrendra Kumar
Link to Judgment
https://patnahighcourt.gov.in/viewjudgment/NSM2NTEjMjAxMyMxI04=-Wd37lLdeMac=
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