The Jharkhand High Court has upheld the conviction and life sentence awarded to Lakhan Kumar Verma and Rahul Kumar Verma in the 2021 murder of Additional District and Sessions Judge Uttam Anand. A Division Bench held that the prosecution had proved beyond reasonable doubt that the collision involving the autorickshaw was intentional and not an accident, leaving no reason to interfere with the trial court's verdict.
Background of the Case
The appeal challenged the judgment of the Special Judge (CBI), Dhanbad, dated July 28, 2022, by which both appellants were convicted under Sections 302/34 and 201/34 of the Indian Penal Code. They were sentenced to life imprisonment without remission or commutation till their last breath, along with fines.
The prosecution case arose from the death of Additional District and Sessions Judge Uttam Anand, who was on his morning walk in Dhanbad on July 28, 2021, when an autorickshaw struck him. The investigation was initially handled by the local police before being transferred to the Central Bureau of Investigation (CBI) due to the seriousness of the incident. The CBI relied on CCTV footage, forensic reconstruction, witness testimony, medical evidence, and scientific analysis during the trial.
Court's Observations
The Division Bench of Justice Rongon Mukhopadhyay and Justice Pradeep Kumar Srivastava examined the extensive evidence produced during the trial, including CCTV recordings, forensic reports, expert opinions, and the circumstances surrounding the incident.
The Bench noted that the scientific evidence consistently indicated that the autorickshaw driver remained in full control of the vehicle and deliberately changed its course toward the deceased before returning to the normal path after the collision.
Referring to the role of the second appellant, the Court observed that the prosecution had successfully established common intention under Section 34 IPC.
The Bench stated:
“The appellant no. 2... was with the appellant no. 1 from the time the auto rickshaw... was stolen till the deliberate and intentional collision was made with the deceased.”
The Court also found that removing the rear number plate and defacing the front number plate of the autorickshaw formed part of the chain of circumstances supporting the prosecution's case.
Rejecting the argument regarding absence of motive, the Court reiterated that where direct and reliable evidence establishes the offence, failure to prove motive is not fatal to the prosecution.
Court's Decision
Dismissing the appeal, the High Court held that the evidence on record clearly established the involvement of both appellants and justified their conviction.
The Bench observed:
“We do not find any rationale to arrive at a different conclusion... we dismiss this appeal.”
Accordingly, the conviction and sentence imposed by the Special Judge (CBI), Dhanbad, remain unchanged.
Pending interlocutory applications were also closed.
Case Details
Case Title: Lakhan Kumar Verma @ Lakhan Verma & Anr. v. Union of India through CBI
Case Number: Criminal Appeal (DB) No. 1578 of 2022
Judges: Justice Rongon Mukhopadhyay and Justice Pradeep Kumar Srivastava
Decision Date: 14 July 2026
