An Attempt to Murder in the Temple of Justice Cannot Be Treated Lightly—When a Bullet Is Fired in Courtroom, Rule of Law Must Roar Louder: Allahabad High Court Upholds Life Sentence

Injury Is Not Just to the Victim But to the Institution—Attempt to Kill Inside a Court Is a Crime Against Justice Itself - Allahabad High Court upholding the life sentence awarded to the appellant under Section 307 IPC and three years rigorous imprisonment under Section 25 of the Arms Act, for firing a shot inside a running courtroom in Shahjahanpur in 1986, targeting Ram Bharose Lal, an accused in a cross-murder case.

The Division Bench comprising Justice Vivek Kumar Birla and Justice Mohd. Azhar Husain Idrisi observed: “When a fire-arm is discharged inside the courtroom while the Presiding Judge is on the dais, it is not merely an attempt to kill—it is an audacious assault on the dignity of the rule of law.”

“A Bullet Was Still Inside the Victim When His Statement Was Recorded—His Testimony Carries a Built-In Guarantee of Truth”

The Court treated the testimony of injured witness Ram Bharose Lal (PW2) as clinching evidence, noting that the victim himself had suffered a gunshot wound in the back at close range, with visible blackening, charring, and tattooing, and the bullet remained inside his body during trial.

The Court relied on consistent legal principles: “The testimony of an injured witness carries a built-in guarantee of presence and reliability. Unless seriously discredited, it must be given full weight.”

It cited several Supreme Court authorities, including Balu Sudam Khalde v. State of Maharashtra and Jarnail Singh v. State of Punjab, affirming the special evidentiary status accorded to victims.

“The Weapon Was Seized from the Accused’s Hands on the Spot—In Presence of Judge, Court Staff, and Witnesses”

The incident occurred during a session trial of a cross-murder case. Accused Gendan Lal had entered the courtroom while his cousin Karan Lal, the complainant in that murder case, was testifying. On being signaled by Karan Lal, Gendan Lal took out a country-made pistol and fired at Ram Bharose, causing serious injury.

The Court noted: “The recovery of the weapon from the accused’s hand with a live and an empty cartridge—inside the courtroom and in presence of court staff—is direct and undeniable proof.”

The presence of PW1 Raja Ram, the complainant and nephew of the victim, and that of PW5 Investigating Officer, was deemed fully established.

“Prosecution’s Star Witness Was the Victim—Presence, Injury, and Identification Are Not in Doubt. The Chain of Evidence Is Unbroken”

Rejecting defence arguments about lack of ballistic reports and failure to examine court staff like Head Moharrir Ram Shanker, the Court held: “When the victim himself saw the assailant immediately after being fired upon, and when the accused was caught on the spot with the weapon in hand, absence of ballistic evidence or other staff is of no legal consequence.”

“Hostile History Does Not Weaken Evidence—Related Witness Is Not Synonymous With Interested Witness”

The Court rejected the contention that PW1 and PW2, being relatives, were "interested witnesses." Relying on Masalti v. State of U.P. and Dharnidhar v. State of U.P., it reiterated: “A relative is not necessarily interested unless proven to be motivated to falsely implicate. The Court must look for consistency and corroboration.”

“The Attack Was an Act of Legal Terrorism—Any Leniency Would Encourage Brazen Disregard for Justice”

The Bench remarked that firing a weapon inside the courtroom is an aggravated form of criminal conduct, deserving no sympathy or reduction in sentence, even though the incident occurred nearly four decades ago.

The Court concluded: “This Court cannot show indulgence merely because the appeal has aged. The rule of law must remain fresh and formidable.”

The Court upheld the judgment dated 25 October 1993, passed by the Sessions Judge, Shahjahanpur, and refused to interfere with the sentence. It held: “The date, time and place are not in dispute. The identity of the assailant is established. There is no room for doubt. The conviction and sentence must stand.”

This case reaffirms the legal position that an attack on life inside a courtroom is an affront not only to an individual but to justice itself. The Allahabad High Court’s judgment is a reminder that law must protect its sanctity with unsparing clarity.

As the Court poignantly put it: “A trial court is not a battlefield—but when violence enters its doors, justice must respond not with hesitation, but with conviction.”

Date of Decision: 25 March 2025