The Patna High Court has acquitted Karpuri Thakur and Balkeshari Devi in a case involving the death of Dinesh Thakur, setting aside their convictions under Sections 304/34 and 323/34 of the Indian Penal Code (IPC). Justice Chandra Shekhar Jha held that inconsistencies in witness testimony, uncertainty about the place of occurrence, and unexplained injuries sustained by the accused raised reasonable doubt about the prosecution's case.
The Court emphasised that establishing a person's death does not, by itself, prove who caused the fatal injuries. Finding the evidence insufficient to sustain the convictions, it allowed the couple's appeal and extended them the benefit of doubt.
Background
The case arose from an alleged altercation on July 16, 2013, connected with a proposed marriage involving Karpuri Thakur's son. According to the prosecution, a confrontation followed, during which Dinesh Thakur and others were allegedly assaulted with sticks and other objects. Dinesh died while being taken to a hospital in Muzaffarpur.
The police registered Sakra Police Station Case No. 335 of 2013 and subsequently filed a charge sheet. In January 2017, the Additional Sessions Judge-III, Muzaffarpur, convicted Karpuri Thakur and Balkeshari Devi under Sections 304/34 and 323/34 IPC, sentencing them to four years and six months of rigorous imprisonment, respectively, with the sentences to run concurrently. They had already been acquitted of charges under Sections 341/34, 324/34 and 307/34 IPC.
The couple challenged their convictions before the High Court, questioning the reliability of the prosecution evidence.
Justice Jha found several weaknesses in the evidence. The informant's testimony did not clearly establish that he had witnessed the assault on the deceased. There were also inconsistencies concerning the timing and location of the incident, while several prosecution witnesses did not support the prosecution's account.
The Court also considered a counter-case arising from the same incident, in which the accused side had reportedly sustained injuries. The prosecution had not produced injury reports for the alleged injured persons, and the injuries to the accused remained inadequately explained.
The judgment observed:
"The factum of homicidal death cannot, by itself, lead to the conclusion that the appellants before the Court were the persons who caused the fatal injuries."
The Court further noted that the alleged incident took place at night, with no satisfactory source of light established to explain how the assailants could have been identified. The medical evidence established the death and the presence of injuries but did not independently identify those responsible.
On the prosecution's burden of proof, the Court reiterated that suspicion cannot replace legally sufficient evidence. It also stressed that the defence need not prove its case beyond reasonable doubt; the prosecution must establish guilt to the required legal standard.
The Court observed that the prosecution's shortcomings had to be assessed collectively rather than in isolation. It noted:
"The discrepancies go to the root of the prosecution case. The difference in time, the uncertain place of occurrence, darkness, the informant's statement that he did not see the deceased at the place of occurrence, the hostile witnesses, the counter-case, the unexplained injuries and the absence of injury reports operate cumulatively and not in isolation."
Allowing the appeal, the High Court set aside the trial court's conviction and sentences against both appellants under Sections 304/34 and 323/34 IPC. It held that the prosecution had failed to establish their guilt beyond reasonable doubt.
The Court ordered that Karpuri Thakur and Balkeshari Devi be acquitted of these offences, extending them the benefit of doubt. Their earlier acquittals under Sections 341/34, 324/34 and 307/34 IPC remained undisturbed.
Since both appellants were on bail, they were discharged from their respective bail bonds and surety liabilities.
Case Details
- Case Title: Karpuri Thakur & Anr. v. State of Bihar
- Case Number: Criminal Appeal (SJ) No. 775 of 2017
- Judge: Justice Chandra Shekhar Jha
- Decision Date: October 15, 2026
