The Supreme Court on March 11, 2026 upheld the acquittal of a man and his wife who had been accused of burning his parents alive in Bihar, saying the prosecution failed to establish guilt beyond reasonable doubt.
A bench of Justices Sanjay Kumar and K. Vinod Chandran observed that the investigation was riddled with serious lapses and appeared to be driven more by public perception than reliable evidence. The Court remarked that an “overzealous investigation” can be just as damaging to the justice system as a careless one.
Read also:- Chhattisgarh High Court Quashes Criminal Complaint Against Judges, Says Allegations Based
Background of the Case
The case arose from a tragic fire that broke out in the early hours of 23 November 2016 in Mahadeopur village, Bihar. The house of an elderly lawyer and his wife was engulfed in flames. The husband died immediately, while his wife succumbed to burn injuries two days later at a hospital in Patna.
Suspicion soon fell on the couple’s younger son and his wife. The prosecution alleged that the son was angry with his father for not giving him his share of ancestral property and had therefore set the house on fire with the intention of killing both parents.
The trial court convicted the accused, relying mainly on alleged dying declarations and witness testimonies suggesting a property dispute.
However, the Patna High Court later acquitted the accused, finding that the evidence did not inspire confidence. The elder son of the deceased then approached the Supreme Court challenging the acquittal.
Read also:- Supreme Court Grants Anticipatory Bail To Folk Singer Neha Singh Rathore In FIR Over Posts On PM
Arguments Before the Supreme Court
The appellant argued that the High Court had ignored crucial evidence, especially the dying declarations allegedly made by the deceased mother. According to him, these statements clearly blamed the son and daughter-in-law for setting the house on fire.
Counsel also submitted that several witnesses corroborated the dying declaration and that the trial court was justified in convicting the accused.
On the other hand, the defence contended that the investigation was deeply flawed and that the alleged dying declarations were inconsistent and possibly influenced by interested witnesses.
Senior counsel for the accused argued that investigators selectively produced witnesses while ignoring independent ones who might have shed light on how the fire actually started.
Read also:- Kerala High Court Quashes Ombudsman Proceedings Against Village Officer, Says He Is Not
Court’s Observations on Dying Declarations
The Supreme Court noted that dying declarations can form the sole basis of conviction if they are trustworthy and free from suspicion. However, the Court emphasised that such statements must inspire confidence and must not appear to be the result of tutoring or prompting.
Examining the evidence, the bench found serious doubts about the reliability of the statements attributed to the deceased woman.
One of the statements recorded as a First Information Statement contained a long narrative about family disputes, which the Court found unlikely from a person suffering severe burn injuries. It also noted that the statement had been recorded in the presence of several villagers and relatives, raising concerns about possible influence.
The second statement recorded by a Block Development Officer also raised questions. There was no medical certification confirming that the victim was in a fit mental condition to give such a statement, and witnesses gave conflicting accounts about who actually recorded it.
The Court concluded that neither of the written declarations inspired confidence.
Read also:- Himachal Pradesh High Court Upholds Termination of Power Board Worker Over Matric Certificate from
Serious Lapses in Investigation
The bench strongly criticised the police investigation, describing it as grossly deficient.
Key shortcomings included the failure to conduct a forensic examination of the burnt house, the absence of a proper scene report, and the failure to investigate whether the fire could have been caused by a gas cylinder explosion as suggested by the defence.
The Court also noted that crucial independent witnesses were never examined, including the woman whose cries reportedly alerted villagers to the fire.
“The investigation, according to us, was a sham and was pre-meditated, throwing to the winds every tenet of criminal jurisprudence,” the bench observed.
Issues with Trial Procedure
Another major concern highlighted by the Supreme Court was the manner in which the accused were questioned during the trial under Section 313 of the Criminal Procedure Code.
The trial court asked only four broad questions and failed to confront the accused with many crucial pieces of evidence, including the alleged motive and the multiple dying declarations relied upon by the prosecution.
The bench noted that such inadequate questioning can cause serious prejudice to the accused and undermine the fairness of the trial.
Read also:- Himachal Pradesh High Court Upholds Termination of Power Board Worker Over Matric Certificate from
Decision
After examining the entire record, the Supreme Court held that the prosecution had failed to establish a complete chain of circumstances linking the accused to the crime.
The Court found that the evidence relied upon by the prosecution was unreliable and that the investigation itself appeared to have been conducted with a predetermined assumption of guilt.
Consequently, the Court affirmed the High Court’s acquittal of the accused and dismissed the appeal.
Case Title: Sanjay Kumar Sharma v. State of Bihar & Ors.
Case No.: Criminal Appeal (Arising out of SLP (Crl.) No. 15378 of 2024)
Decision Date: 11 March 2026
