The Supreme Court of India has upheld the life imprisonment of Ghanshyam Mandal and others in a 1985 double murder case, dismissing their criminal appeal and affirming the findings of both the trial court and the Jharkhand High Court.
In a judgment delivered on February 25, 2026, a Bench of Justice J.K. Maheshwari and Justice Atul S. Chandurkar found no reason to interfere with the conviction under Section 302 read with Section 34 of the Indian Penal Code.
Read also:- Sikkim High Court Closes NHM Transfer Dispute After Amicable Settlement Between Employee
Background of the Case
The case dates back to August 15, 1985. According to the prosecution, a dispute erupted earlier that morning when goats belonging to one of the accused allegedly grazed on the crops of Bulaki Mandal. Heated words were exchanged, and threats were reportedly issued.
Later that afternoon, violence broke out. The informant, Chetan Mandal, told the court that he saw several accused armed with sharp weapons entering his brother’s courtyard. Bulaki Mandal and his nephew Hriday Mandal were dragged out and attacked in the passage near a villager’s house.
The assault, as described by eyewitnesses, continued until both victims fell to the ground and died on the spot.
A sessions court convicted the accused in 1986. The High Court later upheld that conviction in 2019. The present appeal challenged that decision before the Supreme Court .
Read also:- Patna High Court Dismisses Plea for Compensation Over Alleged Illegal Detention, Flags Lapses
Arguments Before the Court
Senior Advocate for the appellants argued that the prosecution witnesses were all related to the deceased and therefore “interested witnesses.” It was also contended that no independent witnesses were examined despite being available.
The defence stressed that the weapons allegedly used in the attack were never recovered. “In the absence of recovery of weapons, the guilt cannot be said to be proved beyond reasonable doubt,” the counsel submitted.
Another major contention related to Section 313 of the Code of Criminal Procedure (CrPC), which requires the court to question the accused about the evidence against them. The appellants claimed that general questions were put to all accused without specifying individual roles, causing prejudice.
The State, however, argued that the four eyewitnesses were consistent and trustworthy. It maintained that recovery of weapons is not mandatory if the oral and medical evidence is reliable.
Read also:- Madras High Court Rules Grandparents Not ‘Family’ for Stamp Duty Concession in Settlement Deeds
Court’s Observations
The Bench closely examined the testimony of the four eyewitnesses and found them consistent. The judges noted that each witness acknowledged the presence of the others at the scene.
“The manner in which the appellants assaulted the deceased has been clearly indicated,” the Court observed. It added that minor inconsistencies in cross-examination did not weaken the prosecution’s case.
On the issue of non-recovery of weapons, the Court relied on earlier precedents and made it clear that recovery is not a strict requirement. “Recovery of the weapons of assault is not the sine qua non for convicting an accused,” the judgment stated, emphasizing that the entire evidence must be considered.
Regarding the Section 313 CrPC argument, the Court acknowledged that the questions put to the accused were somewhat similar. However, it held that unless actual prejudice is shown, such similarity does not invalidate the trial.
Quoting earlier rulings, the Bench underlined that “there cannot be a generalised presumption of prejudice.” In this case, it found that the incriminating circumstances had indeed been put to the accused, and no specific prejudice was demonstrated.
Read also:- Gujarat HC Sends 17-Year-Old Girl to Mehsana Children Home After She Refuses to Return
Decision
After reviewing the evidence, the Supreme Court concluded that the prosecution had proved its case beyond reasonable doubt.
“We do not find any reason whatsoever to hold that the appellants have been wrongly convicted,” the Bench said.
The Court refused to interfere with the life sentence imposed by the Sessions Court and upheld by the High Court. The criminal appeal was dismissed.
Case Title: Ghanshyam Mandal and Ors. v. State of Bihar (Now Jharkhand)
Case No.: Criminal Appeal No. 3105 of 2025
Decision Date: February 25, 2026
