In a tragic case involving the death of two minor girls due to a late-night fire in Khunti, Jharkhand, the Supreme Court of India on August 6, 2025, delivered a split ruling on two connected appeals.
The Court upheld the trial court's conviction of Nilu Ganjhu and Mahboob Ansari while acquitting Dhanushdhari Gaunjhu based on a proven alibi.
The case dates back to the night of April 1-2, 1992. The informant, Santosh Kumar Singh, a bus agent in Khunti, alleged that he had been threatened by local individuals including Nilu Ganjhu and Mahboob Ansari for being an outsider in their territory. Just after 1:45 a.m., a blast occurred, setting his house on fire. While he and his wife managed to escape, their two infant daughters tragically died in the blaze.
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According to the informant, the accused were seen fleeing from the scene under electric light. A case was registered under Sections 302, 307, and 436 of the IPC.
Trial Court Verdict (1994)
On February 9, 1994, the Additional Judicial Commissioner, Khunti, convicted the accused under IPC Sections 436/34 and 302/34, sentencing them to life imprisonment and an additional 7 years’ RI.
High Court Reversal (2023)
However, on January 24, 2023, the Jharkhand High Court set aside the conviction, raising several doubts:
“The learned Trial Court has failed to appreciate... why no remains of the bomb have been found from the place of occurrence.” – Jharkhand High Court
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The High Court also questioned the conduct of the parents in fleeing without the children and highlighted inconsistencies in witness statements and lack of independent testimony.
The Supreme Court clubbed both appeals and ruled separately on each:
1. Conviction Restored for Nilu Ganjhu and Mahboob Ansari
The Court reversed the High Court's acquittal, citing strong eye-witness accounts, consistent medical evidence, and motive.
“The High Court erred in treating this as a purely circumstantial case. The eyewitness (PW1) identified the accused fleeing from the scene under electric light.” – Supreme Court
The Court also noted the emotional trauma and chaotic nature of the incident, rejecting the High Court’s logic regarding the parents’ reactions.
“There cannot be uniformity in human reaction... witnesses may react differently to trauma.” – SC quoting Lahu Kamlakar Patil case
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The judgment directed the convicted accused to surrender within two weeks.
2. Acquittal Confirmed for Dhanushdhari Gaunjhu
The Court upheld the acquittal, accepting the alibi defense. Medical records and credible testimony from Dr. Mahanand Sinha confirmed that the accused was admitted for surgery 38 km away during the incident.
“The Trial Court erred in rejecting the alibi despite solid documentary and medical proof.” – Supreme Court
Case Title: The State of Bihar (now Jharkhand) vs. Nilu Ganjhu @ Nilkant Ram Ganjhu & Others
Date of SC Judgment: August 6, 2025
Criminal Appeals:
- Criminal Appeal No. 3381 of 2025 (SLP (Crl.) No. 10890/2023)
- Criminal Appeal No. 3382 of 2025 (SLP (Crl.) No. 10889/2023)
