Jagannath Chaudhary @ Jagarnath … vs The State Of Bihar on 16 April, 2026

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    Patna High Court

    Jagannath Chaudhary @ Jagarnath … vs The State Of Bihar on 16 April, 2026

              IN THE HIGH COURT OF JUDICATURE AT PATNA
                           CRIMINAL APPEAL (SJ) No.123 of 2004
            Arising Out of PS. Case No.-147 Year-1987 Thana- HUSSAINGANJ District- Siwan
         ======================================================
    1.    Jagannath Chaudhary @ Jagarnath Chaudhary S/O Raghunandan Chaudhary
          @ Raghunath Chaudhary R/O Village- Harihash, P.S- Hussainganj, Dist.-
          Siwan.
    2.   Sheojee Chaudhary S/O Raghunandan Chaudhary @ Raghunath Chaudhary
         R/O Village- Harihash, P.S- Hussainganj, Dist.- Siwan.
    3.    Hari Chaudhary (Abated vide Hon'ble Court's order dated 19-02-2025) S/O
          Raghunandan Chaudhary @ Raghunath Chaudhary R/O Village- Harihash,
          P.S- Hussainganj, Distt.- Siwan.
                                                                   ... ... Appellant/s
                                           Versus
         The State of Bihar
                                                                ... ... Respondent/s
         ======================================================
         Appearance :
         For the Appellant/s    :        Ms. Kumari Chandna, Amicus curiae
                                         Assisted by Ms. Deepali Singh, Amicus curiae
         For the Respondent/s   :        Mrs. Anita Kumari Singh, APP
         ======================================================
           CORAM: HONOURABLE JUSTICE SMT. G. ANUPAMA CHAKRAVARTHY
    
                                      ORAL JUDGMENT
    
                                      Date : 16-04-2026
    
                          1. This appeal is arising out of the
    
          Judgment of conviction and order of sentenced
    
          dated 19.02.2004 passed by Learned District and
    
          Sessions Judge, First Additional Fast Track Court,
    
          Siwan in Sessions Trial No. 135 of 89/133 of 03,
    
          arising out of Hussainganj Police Station Case no.
    
          147 of 1987 whereby, the appellant no.1/Jagannath
    
          Chaudhary             was      convicted           for     the       offence
    
          punishable under Section 324 of Indian Penal Code
    
          (hereinafter          referred       as      the     I.P.C)      and      was
     Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
                                                2/34
    
    
    
    
             sentenced to undergo rigorous imprisonment for a
    
             period of two years, and appellant no.2 and 3,
    
             namely, Sheojee Chaudhary and Hari Chaudhary,
    
             respectively,           were        convicted         for     the    offence
    
             punishable under Section 323 of I.P.C. and were
    
             sentenced to undergo rigorous imprisonment for
    
             one year each.
    
                              2. The judgment of the trial Court reveals
    
             that, altogether, there were five accused before
    
             the      trial        Court.      The       prime          accused     Kedar
    
             Chaudhary, died in the year 2001, therefore, the
    
             criminal case against him stood abated by order of
    
             the trial Court dated 11.02.2002. Further, accused,
    
             Lalan Chaudhary, was acquitted by the trial Court
    
             for the offences punishable under Section 307 r/w
    
             34 of the I.P.C., and this appeal was preferred by
    
             appellant          no.1/Jagannath              Chaudhary,           appellant
    
             no.2/Sheojee Chaudhary, and appellant no.3/Hari
    
             Chaudhary.
    
                              3.     This       Court,           vide     order     dated
    
             04.12.2024

    , called for a report from the

    Superintendent of Police, Siwan, regarding the live
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
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    SPONSORED

    status of the appellants. Pursuant thereto, a report

    was received stating therein that appellant

    no.3/Hari Chaudhary, died. Accordingly, the

    criminal case against him stood abated vide order

    dated 19.02.2025 and the appeal had to proceed

    only against appellant nos. 1 and 2.

    4. As there was no assistance on behalf

    of the appellants, this Court was constrained to

    appoint Ms. Kumari Chandana as amicus curiae.

    However, Ms. Deepali Singh represented the

    amicus curiae and submitted her arguments, which

    are taken on record.

    5. Heard Ms. Deepali Singh and, Ms. Anita

    Kumari Singh Additional Public Prosecutor for the

    State and perused the records.

    6. The case of the prosecution, as per the

    fardbeyan, is that on 31.10.1987 at 06:00 A.M.,

    while Ram Eqbal Choudhary/informant/P.W.-4, was

    sitting at his door, Kedar Choudhary armed with an

    axe, Jagannath Choudhary armed with a spear,

    Hari Choudhary armed with a stick/lathi, and

    Sheojee Choudhary armed with a stick/lathi,
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    surrounded the informant/P.W.-4, abused him,

    when P.W.-4 opposed him, Kedar Choudhary tried

    to hack the informant on his neck. When the

    informant tried to escape, his finger got cut.

    Further in the said incident, Jagannath Choudhary

    hacked P.W.-4 with a spear, due to which he fell on

    the ground sustaining injuries. Thereafter, Hari

    Choudhary and Sheojee Choudhary also attacked

    P.W.-4 with lathis. On witnessing the incident, wife

    of P.W.-4/Sakali Devi/P.W.-3, Amarnath Choudhary/

    his son P.W.-2, and his grandson Surendra

    Choudhary/P.W.-1 tried to save him, but they were

    also attacked by the accused and sustained

    injuries. On the hue and cry of P.W.-4, one Mian,

    Nandlal Choudhary, and Jay Choudhary came to

    the place of occurrence to save P.Ws. 1 to 4 from

    the accused persons, after seeing them, all the

    accused persons fled away. The contents of the

    fardbeyan further disclose that the accused warned

    P.W.-4 to withdraw the case, otherwise they would

    kill him. One day prior to the incident, buffalo of

    P.W.-4 had strayed into the cattle field of the
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    accused, when it could not be traced, P.W.-4

    instituted a case against the accused. The motive

    for the alleged incident is the said case which was

    lodged by P.W.-4.

    7. Basing on the fardbeyan of P.W.-4 dated

    31.10.1987 at 01:00 P.M., recorded by Assistant

    Sub-Inspector B.N. Prasad at Sadar Hospital, Siwan,

    a case was registered against four accused,

    namely, Kedar Choudhary, Jagannath Choudhary,

    Hari Choudhary, and Sheojee Choudhary, for the

    offences punishable under Sections 437, 341, 324,

    323, and 307 r/w 34 of the I.P.C., in connection with

    Hussainganj P.S. Case No. 147 of 1987.

    8. During the course of investigation, the

    Investigating Officer recorded the statements of

    the witnesses, and one Lalan Choudhary was also

    impleaded as an accused. The charge-sheet was

    laid against all five accused, including Lalan

    Choudhary, for the offences punishable under

    Sections 323, 324, and 307 r/w 34 of the I.P.C.

    9. On perusal of the record, it is evident

    that initially charges were framed under Section
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    307 r/w 34 of I.P.C on 28th January 1994. the same

    were read over and explained to all the accused in

    Hindi, to which they all pleaded innocent and

    claimed to be tried.

    10. The record reveals that the date of the

    incident, as per the fardbeyan, was 31.10.1987.

    Hari Choudhary and Sheojee Choudhary

    surrendered before the Court on 10.11.1987 and

    were granted bail on the same day. The record also

    reveals that the sessions trial record was

    transferred to different courts, and after closure of

    the prosecution evidence, the accused were

    examined under Section 313 of the Cr.P.C. Later,

    accused/Lalan Choudhary surrendered before the

    Chief Judicial Magistrate on 28.04.1988, and

    thereafter, he was enlarged on bail. Jagannath

    Choudhary surrendered on 12.11.1987, and on the

    same day, he was also granted bail. But the

    judgment was delivered on 19.02.2004.

    11. During the course of trial, the

    prosecution has examined altogether five

    witnesses and marked five Exhibits which are as
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    follows:-

              P.Ws.No            P.W.s Name                      Relation
              P.W. 1             Surendra Chaudhary              Grandson of
                                                                 informant
              P.W. 2             Amarnath Chaudhary              Son of
                                                                 informant
              P.W. 3             Sakali Devi                     Wife of
                                                                 informant
              P.W. 4             Ram Iqbal Chaudhary Informant
              P.W. 5             Dr. Anil Kr. Verma              Doctor
    
    
              Sl. No. Exhibit                   Exhibit Details
              1.             Ext. 1             Fardbeyan of Ram Iqbal
                                                Chaudhary
              2.             Ext. 2             Injury report of Ram Iqbal
                                                Chaudhary
              3.             Ext. 2/1           Injury report of Surendra
                                                Chaudhary
              4              Ext. 2/2           Injury report of Sakali Devi
              5.             Ext. 2/3           Injury report of Amarnath
                                                Chaudhary
    
    
    
    

    12. After considering the entire material

    available on record, the trial court convicted and

    sentenced the appellant no.1/Jagannath Chaudhary

    for the offence punishable under Section 324 and

    appellant no.2/Sheojee Chaudhary for the offence

    punishable under Section 323 of the I.P.C.

    13. The points for determination in the
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    appeal are :-

    (i) Whether the prosecution is

    able to prove the guilt of the appellants for

    the offences punishable under Sections 324

    and 323 of I.P.C. beyond reasonable doubt?

    (ii) Whether the trial Court is right

    in convicting and sentencing appellant no.

    1 for the offence punishable under Section

    324 of the IPC and appellant no. 2 for the

    offence punishable under Section 323 of

    the IPC?

    14. In order to decide the aforesaid points

    for determination, it is just necessary to re-

    appreciate the evidence on record.

    15. It is pertinent to mention that P.W.-1 to

    3 are the grandson, the son, and wife of the

    informant/P.W.-4, who are alleged to have been

    injured in the said incident along with P.W.-4. It is

    also relevant to mention that, initially, Lalan

    Chaudhary was not arrayed as an accused in the

    F.I.R., as there was no allegation against him in the

    fardbeyan. However, Lalan Chaudhary was
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    impleaded as an accused, but was acquitted by the

    trial Court for the offence punishable under Section

    307 r/w 34 of the I.P.C.

    16. P.W.-1, Surendra Chaudhary, the

    grandson of P.W.-4, testified that the accused Kedar

    was holding an axe, Jagannath Chaudhary was

    holding a spear, and others were carrying lathis.

    They abused P.W.-4, when he refuted them, Kedar

    Chaudhary tried to hack his grandfather on the

    neck with an axe, and when his grandfather moved

    back, his left thumb got cut. He also testified that

    Jagannath Chaudhary, tried to hack his grandfather

    on his forehead with a spear, due to which, his

    grandfather fell down and the other accused

    persons assaulted his grandfather with sticks.

    When he tried to save his grandfather, Lalan

    Chaudhary hit him with a lathi on his left elbow.

    Sheojee, Hari, and Lalan also assaulted his

    grandmother with sticks. Further, Sheojee and Hari

    assaulted his uncle (P.W.-2) with lathis on both the

    legs.

    17. In cross examination, it is specifically
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    stated by P.W. 1 that there was enmity with the

    appellants. Further, sticks were in the hands of

    Sheojee Hari and Lalan Chaudhary. He denied the

    suggestion that his grandmother was returning

    from shop after purchasing items, and that Lalan

    and Sheojee did not assaulted his grandmother.

    18. The evidence of P.Ws.-2 and 3 is also

    on the same lines as that of P.W.-1. However, their

    evidence disclose presence of Lalan Chaudhary

    along with other appellants, at the place of

    occurrence, as well as his participation in the said

    occurrence. In cross-examination, it is specifically

    testified by P.W.-2 that his grandfather (P.W.-4)

    preferred a case against all appellants, five to six

    days prior to the incident before the Inspector of

    Hussainganj. His evidence also disclose that the

    accused/ Kedar, tried to attack his father with an

    axe, and when P.W.-4 tried to stop it, his father’s

    finger got cut. It is further testified by P.W.-2 that

    his mother went to buy vegetables, and in the

    alleged incident, all the ration got by her scattered.

    19. P.W.-3 also stated about the presence
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    of Lalan Chaudhary along with the other accused.

    In cross-examination, it is testified by P.W.-3 that he

    was treated at the Government Hospital, Siwan,

    and did not know whether there is a Government

    Hospital at Hussainganj or not?

    20. P.W.-4/ Ram Eqbal Chaudhary, is the

    informant. His evidence disclose that the incident

    occurred 6-7 years prior to his examination before

    the trial Court. He deposed that at that particular

    point of time, he was sitting at the door, and all the

    accused, including Lalan Chaudhary, armed with

    weapons, reached there, and Kedar hit him with an

    axe. When he tried to stop him, his fingers got cut.

    Further, Jagannath hit him on his forehead, and on

    his hue and cry, his wife, son and grandson

    reached the place of occurrence, where Lalan hit

    his grandson (P.W.-1) with a lathi, and Sheojee hit

    Amarnath (P.W.-2) on his back. Further, Sheojee

    also hit his wife on her hip, and Hari hit her on her

    back with a stick. He further testified that the

    witness Nandlal Chaudhary died two years earlier,

    and Jai Chaudhary and another had colluded with
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    the accused, and as such, he was not in a position

    to examine the independent witnesses on his

    behalf. His evidence further disclose that he had

    preferred a case against the appellants before the

    police station; However, the said document was

    not marked. He was treated at the Government

    Hospital, Siwan, where the Sub-Inspector of Police

    recorded his statement, which is marked as Ext. 1

    (Fardbeyan).

    21. In cross-examination, it is specifically

    testified by P.W.-4 that the appellants attacked him

    with an axe, and when he tried to rebut the axe

    with his hand, he sustained a cut injury on his

    palm. It is further testified by P.W.-4 that Jai

    Chaudhary was the a prime witness, who colluded

    due to fear of the accused, and that the

    statements of other witnesses were also recorded

    in the hospital. However, the fardbeyan of P.W.-4

    does not disclose either the alleged attack made

    by the appellants from his behind or about the

    presence of Lalan Chaudhary.

    22. P.W.-5/ Dr. Anil Kumar Verma, deposed
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    that on 31.10.1987 at about 10:00 A.M., at the

    hospital he examined P.W.-4/ Ram Eqbal

    Chaudhary, and found the following injuries:

    (i) Sharp cut wound on the left lateral side
    of the forehead, measuring 1/2″ x 1/2″ x bone
    deep.

    (ii) Lacerated wound on the lateral side of
    the thumb, 1/4″ x 1/3″ x bone deep.

    (iii) Lacerated wound on the back of the
    middle finger in the upper portion, 1/3″ x 1/4″ x
    bone deep.

    (iv) Abrasion on the front of the left knee,
    1/3″ x 1/3″ x 1/3″. All the injuries sustained by P.W.-

    4 were simple in nature.

    I. On the same day, at 10:20 A.M., he

    examined P.W.-1/ Surendra Chaudhary, and found

    one injury, i.e., a linear bruise on the back of the

    left forearm, 2″ above the elbow joint, 1-½” x 1/2″,

    which was simple in nature.

    II. P.W.-5 further testified that he also

    examined P.W.-3/ Sakala Devi, and found two

    injuries of simple in nature, which are as follows:

    (i) Bruise on the right scapular region, 1/4″

    x 2/3″.

    (ii) Bruise on the left iliac region, 2″ x 2/3″.
    III. P.W.-5 also testified that he examined
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    P.W.-2/ Amarnath Chaudhary, at 10:25 A.M. on the

    same day and found the following injuries of simple

    in nature:

    (i) Bruise on the left lateral side of the leg,
    2-2 1/2″ above the ankle joint, measuring 1-1/2″ x
    1″.

    (ii) Tenderness over the calf muscle.

    IV. The injury reports of P.Ws.-4, 1, 3, and

    2 were marked as Exts. 2, 2/1, 2/2, and 2/3,

    respectively.

    23. On perusal of the entire evidence, it is

    evident that all four witnesses have improved their

    version from the contents of the fardbeyan by

    stating the presence of Lalan Chaudhary at the

    scene of the offence, along with the other accused,

    which was disbelieved by the trial Court.

    24. It is argued by Ms. Deepali Singh, on

    behalf of the learned amicus curiae, that there are

    inconsistencies and discrepancies in the evidence

    of P.Ws.-1 to 4, who are admittedly related to each

    other; It is further submitted that no independent

    witnesses were examined for reasons best known

    to the prosecution. Therefore, prayed to extend
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    the benefit of doubt to the appellants, particularly

    when the trial Court has failed to accord due

    consideration to the principle of parity in criminal

    jurisprudence. It is specifically contended that

    when the co-accused were similarly situated, and

    the evidence adduced against them is identical;

    therefore, the Court cannot adopt different

    standards of appreciation so as to convict one

    while acquitting another unless there exist

    distinguishing features.

    25. Admittedly, P.Ws.-1 to 4, in one tone,

    have stated about the presence of Lalan

    Chaudhary and also the overt act attributed to him.

    As stated supra, the name of Lalan Chaudhary was

    not in the F.I.R., as there was no specific allegation

    against him in the fardbeyan of P.W.-4; however,

    the role of Lalan Chaudhary has been stated by all

    the witnesses.

    26. In this context, she relied on the

    following judgments of the Hon’ble Apex Court. In

    the case of Yogarani V. State by the Inspector

    of Police, reported in 2024 SCC OnLine SC
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    2609, their Lordships have held as follows:

    10. The Court cannot
    convict one accused and acquit
    the other when there is similar or
    identical evidence pitted against
    two accused persons. In the case
    of Javed Shaukat Ali Qureshi v.

    State of Gujarat reported in 2023
    INSC 829, this court has held that:

    “15. When there is
    similar or identical evidence
    of eyewitnesses against two
    accused by ascribing them
    the same or similar role, the
    Court cannot convict one
    accused and acquit the
    other. In such a case, the
    cases of both the accused
    will be governed by the
    principle of parity. This
    principle means that the
    Criminal Court should
    decide like cases alike, and
    in such cases, the Court
    cannot make a distinction
    between the two accused,
    which will amount to
    discrimination.”

    27. In case of Javed Shaukat Ali Qureshi

    Vs. State of Gujarat reported in (2023) 9 SCC

    164, wherein their Lordships have held as follows:

    15. When there is similar or
    identical evidence of eyewitnesses
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    against two accused by ascribing
    them the same or similar role, the
    court cannot convict one accused
    and acquit the other. In such a case,
    the cases of both the accused will be
    governed by the principle of parity.

    This principle means that the
    criminal court should decide like
    cases alike, and in such cases, the
    court cannot make a distinction
    between the two accused, which will
    amount to discrimination.

    28. In case of Ajmer Singh Vs. State of

    Haryana reported in (2010) 3 SCC 746, wherein

    their Lordships have held as follows:

    23. The principle of parity in
    criminal case is that, where the case
    of the accused is similar in all
    respects as that of the co-accused
    then the benefit extended to one
    accused should be extended to the
    co-accused. With regard to this
    principle, it is important to mention
    the observation of this Court in
    Harbans Singh v. State of U.P.
    [(1982) 2 SCC 101 : 1982 SCC (Cri)
    361] In that case it was held, that, in
    view of commutation of death
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    sentence of one of the accused, who
    was similarly placed as that of the
    appellant, award of death sentence
    to the appellant was unjustified and
    hence, the death sentence of the
    appellant was stayed till the decision
    of the President on commutation of
    sentence.

    29. In case of Balkar Singh Vs. State of

    Punjab reported in 1984 SCC OnLine P&H 441,

    wherein his Lordship has held as follows:

    5. As already noticed above,
    the learned Additional Sessions
    Judge has placed reliance on the
    same set of witnesses in the case
    under section 61 (1)(c) of the Act
    whereas they have been disbelieved
    in the case under section 61 (1) (a)
    of the Act. Both the offences are said
    to have been committed in the same
    transaction. This fact also clouds the
    prosecution case with doubt. If in the
    same transaction the witnesses are
    disbelieved regarding the
    commission of one offence their
    testimony becomes unreliable with
    regard to the other offence also. It is
    an additional factor which persuades
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    me to decline to affirm the impugned
    judgment of the learned Additional
    Sessions Judge.

    30. In case of Yogesh Alias Sachin

    Jagdish Joshi Vs. State of Maharashtra

    reported in (2008) 10 SCC 394, wherein their

    Lordships have held as follows:

    28. We are, therefore, of the
    view that in the light of the
    subsequent events, namely, the
    orders of the High Court dated 7-7-

    2006 in Criminal Writ Petitions Nos.
    1283-84 of 2006, discharging the
    appellant’s mother, sister and two
    close associates, Accused 2, 4, 11
    and 12 respectively; order dated 30-

    4-2007 passed by this Court
    dismissing the special leave petition
    preferred by the State against order
    dated 7-7-2006 and order dated 14-

    5-2007 passed by the Sessions
    Judge, Satara, discharging the father
    (A-1) of the appellant, stated to be
    the mastermind behind the entire
    conspiracy, for offences under
    Sections 120-B and 302 IPC, on same
    set of circumstances and
    accusations, no sufficient ground
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    survives to proceed against the
    appellant for the aforementioned
    offences.

    31. All the above citations squarely apply

    to the facts and circumstances of the present case.

    32. It is further argued on behalf of the

    amicus curiae that non-examination of the

    Investigating Officer vitiates the case of the

    prosecution, inasmuch as prejudice is caused to

    the appellants. It is specifically contended that the

    examination of the Investigating Officer establishes

    the place of occurrence, as well as the recovery or

    non-recovery of the alleged weapons or material

    objects from the place of occurrence, and also

    relates to the motive for the offence and whether

    there existed any prior enmity between the parties.

    33. In respect of the above, Ms. Deepali

    Singh, appearing on behalf of the amicus curiae,

    relied on the following judgments. In the case of

    S.K. Rashid @ Abdul Rashid and Another v.

    State of Bihar, reported in 1986 SCC OnLine

    Pat 221, their Lordships have held as follows:

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    8. True, non-examination of
    Investigating Officer is not
    necessarily fatal to the prosecution.

    A Court has to see whether the
    evidence of the Investigating Officer
    is essential for the case of the
    prosecution to succeed or not. The
    Court has to see at the same time
    that the accused is not unnecessarily
    harassed and unless it seems that
    for unavoidable reasons the
    prosecution fail to produce the
    Investigasing Officer, it may
    pronounce the judgment without the
    evidence of the investigating Officer.
    The Court, if it is satisfied that the
    evidence of the Investigating Officer
    is essential, must take coercive
    measures to compel his attenance as
    a witness. Difficulty, however, which
    the Courts in Bihar face, is that even
    for executing the process of the
    Court help of police hierarchy is
    necessary. Without them and without
    they desiring to implement the
    summons and warrants of the
    Courts, all efforts of the Courts for
    securing the attendance of the
    witnesses fail. What has alarmed us,
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    however, is the recessive tendency
    of the police personnel. They are
    taking the process of the Courts as
    lazily and as casually as they can,
    they have no priorities for the
    proceedings in the Courts over
    attending to other works for which
    they have their reasons of
    preference. As in this case in many
    cases Courts have to face a
    predicaments which the prosecution
    done can solve, when it does
    however, is but to tell the Court that
    it has no other witnesses to examine
    and to take summons only to inform
    the Court that it has heard nothing
    from the police about the service
    thereof. Several adjournments given
    by the Court at the instance of the
    prosecutor only for ensuring the
    attendance of the official witnesses
    including the Investigating Officer
    keep the trials pending for years and
    even after inordinate wait, the
    Courts are compelled to decide the
    cases without their evidence. A
    certain amendment has been made
    in the Code of Criminal Procedure by
    the State of Uttar Pradesh and for
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    23/34

    such defaulting witnesses adequate
    provisions have been made to
    punish both judicially and
    admistratively. It is high time that in
    the State of Bihar also some
    provisions are made and in the case
    it is found that a certain officer of
    the State has ignored the summons
    or warrant of the Court, adequate
    action is taken against him. The
    administration of the State, even
    without any such amendment, is
    fully empowered and competent to
    take notice of the defaults of its
    officers in responding to the
    summons and warrants of the Court
    and it can immediately start taking
    notice of the conduct of the
    Investigating Officers of the police by
    suitably punishing them by awarding
    Black marks at least two for default
    in each case. We cannot satisfy our
    concern by nearly making these
    observations and we feel that in the
    ends of justice a direction to this
    effect to the State of Bihar is
    necessary and we, accordingly,
    direct the State of Bihar to take
    administrative notice of the default
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
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    of its officers in not responding to
    the summons and warrants of the
    Courts for their appearance as
    witnesses and after giving them
    opportunity to show cause to award
    suitable punishment, as their
    defaults cause injury to justice. Such
    defaults, undoubtedly, are acts of
    indiscipline and inefficiency. To begin
    with the Sessions Judges in each
    Sessions Division of the State shall
    be well advised to furnish to the
    District Magistrate and the
    Superintendent of Police of each
    administrative district of the State a
    list of pending cases in which official
    witnesses have not respondent to
    the summons and the warrants and
    also the list of the case which for
    default in serving summons and
    warrants the cases are awaiting
    disposal and the District Magistrate
    and District Superintendent of Police
    shall be well advised to take
    administrative action to ensure
    attendance of such official witnesses
    in the Court and execution of the
    proceeding this Court should issue a
    circular forthwith to all Sessions
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    25/34

    Judges to comply with this procedure
    and the State of Bihar should issue
    circulars to the District Magistrate
    and the District Superintendents of
    Police to comply with the demands
    of the Courts for examination of the
    Witnesses in the trials.

    34. In case of Behari Prasad and

    Others. V. State of Bihar, reported in (1996) 2

    SCC 317, their Lordships have held as follows:

    23. It, however, appears to
    us that the entire case diary should
    not have been allowed to be
    exhibited by the learned Additional
    Sessions Judge. In the facts of the
    case, it appears to us that the
    involvement of the accused in
    committing the murder has been
    clearly established by the evidences
    of the eyewitnesses. Such evidences
    are in conformity with the case made
    out in FIR and also with the medical
    evidence. Hence, for non-

    examination of Investigating Officer,
    the prosecution case should not fail.
    We may also indicate here that it will
    not be correct to contend that if an
    Investigating Officer is not examined
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
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    in a case, such case should fail on
    the ground that the accused were
    deprived of the opportunity to
    effectively cross-examine the
    witnesses for the prosecution and to
    bring out contradictions in their
    statements before the police. A case
    of prejudice likely to be suffered by
    an accused must depend on the
    facts of the case and no universal
    strait-jacket formula should be laid
    down that non-examination of
    Investigating Officer per se vitiates a
    criminal trial. These appeals,
    therefore, fail and are dismissed. The
    appellants who have been released
    on bail should be taken into custody
    to serve out the sentence.

    35. In case of Lahu Kamlakar Patil and

    Another V. State of Maharashtra, reported in

    (2013) 6 SCC 417, their Lordships have held as

    follows:

    18. Keeping in view the
    aforesaid position of law, the
    testimony of PW 1 has to be
    appreciated. He has admitted his
    signature in the FIR but has given
    the excuse that it was taken on a
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
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    blank paper. The same could have
    been clarified by the investigating
    officer, but for some reason, the
    investigating officer has not been
    examined by the prosecution. It is an
    accepted principle that non-

    examination of the investigating
    officer is not fatal to the prosecution
    case. In Behari Prasad v. State of
    Bihar
    [(1996) 2 SCC 317 : 1996 SCC
    (Cri) 271] , this Court has stated that
    non-examination of the investigating
    officer is not fatal to the prosecution
    case, especially, when no prejudice
    is likely to be suffered by the
    accused.
    In Bahadur Naik v. State of
    Bihar
    [(2000) 9 SCC 153 : 2000 SCC
    (Cri) 1186] , it has been opined that
    when no material contradictions
    have been brought out, then non-

                                    examination             of     the    investigating
                                    officer        as       a     witness     for      the
    

    prosecution is of no consequence
    and under such circumstances, no
    prejudice is caused to the accused. It
    is worthy to note that neither the
    trial Judge nor the High Court has
    delved into the issue of non-

    examination of the investigating
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    28/34

    officer. On a perusal of the entire
    material brought on record, we find
    that no explanation has been
    offered. The present case is one
    where we are inclined to think so
    especially when the informant has
    stated that the signature was taken
    while he was in a drunken state, the
    panch witness had turned hostile
    and some of the evidence adduced
    in the court did not find place in the
    statement recorded under Section
    161
    of the Code. Thus, this Court in
    Arvind Singh v. State of Bihar [(2001)
    6 SCC 407 : 2001 SCC (Cri) 1148] ,
    Rattanlal v. State of J&K [(2007) 13
    SCC 18 : (2009) 2 SCC (Cri) 349] and
    Ravishwar Manjhi v. State of
    Jharkhand [(2008) 16 SCC 561 :

                                    (2010)        4     SCC           (Cri)    50]     ,    has
                                    explained            certain          circumstances
                                    where             the             examination            of
    

    investigating officer becomes vital.
    We are disposed to think that the
    present case is one where the
    investigating officer should have
    been examined and his non-

    examination creates a lacuna in the
    case of the prosecution.

    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    29/34

    36. All the above citations squarely apply

    to the facts and circumstances of the present case.

    37. It is also contended by Ms. Deepali

    Singh, on behalf of amicus curiae that the trial

    Court has sentenced the appellants for the

    offences punishable under Sections 323 and 324 of

    the I.P.C., though they were also charged for the

    offence punishable under Section 307 of the I.P.C.,

    and by imposing such sentence, the trial Court

    ought to have given a clear finding regarding

    acquittal and conviction for the offence punishable

    under Section 307 r/w Section 34 of the I.P.C., and

    also for invoking Section 222 of the Cr.P.C. for

    awarding a lesser punishment for the major

    offence.

    38. The Court cannot adopt different

    standards of appreciation to convict one and to

    acquit another, unless there exist distinguishing

    features. Admittedly, in the present case, Lalan

    Chaudhary was acquitted, and the other three

    appellants were convicted for the offences

    punishable under Sections 323 and 324 of the
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    30/34

    I.P.C.; therefore, the appellants are also entitled to

    the same benefit as that of Lalan Chaudhary.

    39. Admittedly, in the present case, the

    Investigating Officer was not examined for reasons

    best known to the prosecution. Generally, the non-

    examination of the Investigating Officer is not fatal

    to the case; however, in the present case, the

    place of occurrence was not established, and there

    is no evidence on record as to the recovery of the

    weapons or material objects from the place of

    occurrence or about the motive or enmity for the

    offence.

    40. On perusal of the entire judgment of

    the trial Court, it is evident that the prosecution

    has miserably failed to prove the guilt of the

    appellants for the offence punishable under

    Section 307 r/w 34 of the I.P.C., and therefore, the

    trial Court ought to have acquitted other accused

    of the offence punishable under Section 307 r/w 34

    of the I.P.C. However, the trial Court has convicted

    appellant no.1 for the offence punishable under

    Section 324 of the I.P.C. and appellant no.2 for the
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    31/34

    offence punishable under Section 323 of the I.P.C.

    It is the case of the prosecution that all the

    accused were armed with weapons. In case, the

    appellants were armed with weapons, Section 324

    of the I.P.C. is attracted and not Section 323 of the

    I.P.C.; therefore, the trial Court ought to have

    convicted appellant no.2 also for the offence

    punishable under Section 324 of the I.P.C. In the

    present case, the conviction of appellant no.2

    under Section 323 of the I.P.C. shows non-

    application of mind while rendering the judgment.

    It is the duty of trial Court to ensure that the

    conviction under Section 324 is based on solid

    criminal evidence, and not merely as a

    compromise to validate the informant’s property

    claim. However, there is no evidence on record to

    prove that these injuries were sustained by the

    prosecution witnesses with the weapons as stated

    by them in their oral evidence. Furthermore, P.Ws.-

    1, 2, and 3 sustained only bruises on their bodies,

    which do not prove the guilt of the appellants. As

    per the evidence of P.Ws.-1 to 4, Jagannath
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    32/34

    Chaudhary was holding a spear. If at all P.Ws.-1 to

    3 sustained injuries on the hands of Jagannath

    Chaudhary, there ought to have been incised

    wounds on their bodies, and not bruises.

    41. P.W.-4 also sustained only simple

    injuries. If at all an axe or spear was inflicted upon

    P.W.-4, he would have sustained incised wounds.

    The weapons stated by all the witnesses to have

    been used against P.W.-4 were an axe and a spear.

    It is the specific evidence of P.Ws.-1 to 4 that

    initially Kedar Chaudhary tried to hack the neck of

    P.W.-4, and when P.W.-4 took a step backward, his

    left thumb and middle finger got cut. However, the

    injury report (Ext. 2) shows only lacerated wounds

    and no cut injuries.

    42. On perusal of the entire evidence as

    well as the judgment of the trial Court, this court

    finds it surprising as to how Lalan Chaudhary was

    acquitted by the trial Court. The sole reason given

    by the trial Court appears to be that the age of

    Lalan Chaudhary was recorded as 30 years at the

    time of his examination under Section 313 of the
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    33/34

    Cr.P.C., and about therefore approximately 16½

    years prior to the examination, he would have

    been about 13½ years of age; on such premise,

    the trial court concluded that he would have been

    falsely implicated in the present case. Admittedly,

    birth certificate of Lalan Chaudhary is not before

    the Court to prove his age, and there is no other

    evidence on record to establish that the age of

    Lalan Chaudhary was 13½ years as on the date of

    the alleged incident. However, considering the

    principles of parity in criminal jurisprudence, this

    Court is of the considered opinion that the same

    benefit has to be extended to the other appellants

    also, as they are similarly situated and the

    evidence against them is identical in nature.

    43. In view of the aforesaid discussions,

    this Court is of the considerable view that the trial

    Court has erred in convicting the appellants for the

    offence punishable u/s 324 and 323 I.P.C. and as

    such, the judgment of trial Court is liable to be set

    aside.

    44. Accordingly, the judgment of
    Patna High Court CR. APP (SJ) No.123 of 2004 dt.16-04-2026
    34/34

    conviction dated and order of sentence dated

    19.02.2004, on the file of the Learned District and

    Sessions Judge, First Additional Fast Track Court,

    Siwan in sessions Trial No. 135/89/133/03 arising

    out of Hussainganj Police Station no. 147 of 1987,

    is hereby set aside, and the appellants are

    acquitted for the aforesaid offences.

    45. In result, the appeal is hereby

    allowed.

    46. The record reveals that the

    appellants were released on bail by this Court vide

    order dated 03.03.2004. In view of the acquittal of

    the appellants, the bail bonds of both the

    appellants shall stand cancelled.

    47. Let the records be transmitted to the

    trial Court.

    (G. Anupama Chakravarthy, J)
    AMANDEEP/-

    AFR/NAFR                NARF
    CAV DATE                N/A
    Uploading Date          07.05.2026
    Transmission Date       07.05.2026
     



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