The Allahabad High Court has allowed a 42-year-old criminal appeal and set aside a conviction for murder under Section 302 read with Section 34 of the Indian Penal Code, holding that the prosecution failed to establish guilt beyond reasonable doubt and observing that extraordinary delay in disposal of criminal proceedings undermines the ends of justice.
A Division Bench comprising Justice Chandra Dhari Singh and Justice Sanjiv Kumar overturned the judgment of conviction and life sentence passed in 1984 by the Additional Sessions Judge, Hamirpur, arising from an incident dating back to August 1982. The appeal remained pending before the High Court for over four decades, during which the appellant was on bail.
Upon a re-appreciation of evidence, the Court found the prosecution case to be riddled with material contradictions and inconsistencies, including discrepancies between medical and ocular evidence, doubtful preparation of the FIR, unreliable eyewitness testimony, and absence of a clearly established motive. The Bench held that these infirmities struck at the root of the prosecution case and entitled the appellant to the benefit of doubt.
The Bench noted that the appellant was now around 100 years of age, and had lived for decades under the weight of an unresolved criminal prosecution. It observed that when a criminal appeal remains pending for such an extraordinary length of time, the process itself begins to assume the character of punishment, even in the absence of final adjudication.
Placing reliance on settled Supreme Court jurisprudence, the High Court held that advanced age of the accused, long passage of time, uninterrupted liberty on bail, and systemic delay are all relevant considerations while moulding relief. The Court emphasised that punishment must bear a rational nexus to its objectives of deterrence, retribution, and reformation, and that these objectives stand diluted when proceedings linger across generations.
The Bench further observed that the constitutional guarantee of fair and reasonable procedure extends beyond the stage of trial and includes the right to timely conclusion of appellate proceedings. Where the justice delivery system itself fails to provide finality within a reasonable period, courts are justified in adopting a humane and pragmatic approach.
Holding that continuing penal consequences at such an advanced stage of life would serve no useful purpose, the High Court set aside the conviction, acquitted the appellant of all charges, and discharged the bail bonds.
Cases Relied/Referred:
On appreciation of evidence, benefit of doubt & standard of proof:
1. Vadivelu Thevar v. State of Madras, AIR 1957 SC 614
2. Pankaj v. State of Rajasthan, (2016) 16 SCC 192
3. Bhagwan Sahai v. State of Rajasthan, AIR 2016 SC 2714
4. Kannaiya v. State of Madhya Pradesh, 2025 INSC 1246
5. State of U.P. v. Kishore Gopal Das, AIR 1988 SC 2154
6. Ramakant Rai v. Madan Rai, (2003) 12 SCC 395
7. Goverdhan v. State of Chhattisgarh, (2025) 3 SCC 378
8. Jitendra Kumar Mishra v. State of Madhya Pradesh, 2024 INSC 20
On pendency, delay, advanced age & moulding relief
1. State of Madhya Pradesh v. Shyamlal & Ors., 2025 INSC 377
2. Fatta v. State of U.P., 1980 Supp (1) SCC 159
Appearances:
Counsel for Appellant(s) : Ram Bahadur, Ramesh Prajapati, S.k.srivastava
Counsel for Respondent(s) : A.G.A., D.g.a
