Tractor-Run-Over Death Was An Accident, Not Murder: Allahabad High Court Acquits Three Accused

"The Possibility Of The Present Appellants Being Falsely Implicated On Account Of Previous Enmity Cannot Be Ruled Out", In a significant ruling that underscores the evidentiary weight of unexplained delay in criminal prosecutions, the Allahabad High Court on March 18, 2026 set aside the life imprisonment awarded to three accused persons convicted for the murder of Mohammad Rafi, who allegedly died after being run over by a tractor in Rampur district.

A Division Bench of Hon'ble Justice Chandra Dhari Singh and Hon'ble Justice Devendra Singh-I held that the prosecution had failed to establish guilt beyond reasonable doubt, and that the incident bore all the hallmarks of an accidental death that had been deliberately coloured as homicide on account of prior enmity.

The case arose from an incident on March 7, 2013, when Mohammad Rafi, aged about 25 years, was allegedly run over by a tractor near the culvert of village Khaudpura in Rampur district at around 7:00 AM. First informant Mohammad Yusuf, uncle of the deceased, lodged an FIR at Police Station Bhot on March 9, 2013 — more than 49 hours after the incident — alleging that accused Faeem deliberately drove a tractor over Rafi while accused Irfan and Saleem, seated on the tractor's mudguards, instigated him to kill. The Sessions Judge, Rampur convicted all three accused, sentencing them to life imprisonment under Sections 302 and 120B IPC. Aggrieved by the conviction, the appellants approached the Allahabad High Court.

The central legal questions before the Court were whether the death was homicidal or accidental, whether the delay of over 49 hours in lodging the FIR was satisfactorily explained, and whether the eyewitness testimony was reliable enough to sustain a conviction for murder.

On the Question of Homicidal Death Versus Accidental Death

The Court's attention was drawn to a crucial piece of documentary evidence — Exhibit Ka-17, a letter dated March 7, 2013 written by Dr. Rakesh Kumar to the Incharge Inspector, Kotwali, Rampur — which recorded that Mohammad Rafi was admitted to the District Hospital, Rampur at 7:40 AM as "an accidental injury case" who died at 8:40 AM. The Court found it deeply significant that the hospital itself had categorised the admission as accidental. Furthermore, defence witness DW-1, Firasat Husain, deposed that he had personally witnessed the incident while travelling by car and that a tractor-trolley loaded with sugarcane, coming from the side of Thunapur, had hit the motorcycle of the deceased — confirming it was a road accident.

The Court pointedly observed: "It was an accidental death and the accused-appellants have falsely been dragged in this case after due deliberation and that the first information report has been lodged after two days for which no plausible explanation has been tendered by the prosecution."

On the 49-Hour Delay in Lodging the FIR

The Court undertook a careful examination of the law on delayed FIRs, drawing upon a line of Supreme Court precedents. Citing Mukesh v. State of NCT of Delhi (2017) 6 SCC 1, the Court noted that delay in setting the law into motion is normally viewed with suspicion because "there is possibility of concoction of evidence against an accused" and it becomes necessary for the prosecution to satisfactorily explain the delay. The Court further relied upon Hari Lal v. State of Madhya Pradesh 2023 SCC OnLine SC 1124, which held that "when an FIR is delayed, in absence of proper explanation, the courts must be on guard and test the evidence meticulously to rule out possibility of embellishments in the prosecution story, inasmuch as delay gives opportunity for deliberation and guess work."

Applying these principles, the Court found that PW-1 Mohammad Yusuf's explanation for the delay was wholly unreasonable. The first informant himself admitted in cross-examination that he did not lodge any report on March 7, 2013, despite being present at the hospital when his nephew died and despite eyewitnesses PW-2 and PW-3 being available. The FIR was lodged only on March 9, 2013 — a delay of over 49 hours — which the Court held created serious doubt about whether the prosecution version had been fabricated through deliberation during that interval.

On the Reliability of Eyewitnesses — Internal Contradictions That Sank the Prosecution

The Court identified a fatal internal contradiction between the testimonies of the prosecution's own witnesses. PW-1 Mohammad Yusuf stated in his examination-in-chief that when he was taking the injured to the hospital, PW-2 Iftekhar Husain and PW-3 Arshad Ali were with him and had helped him. However, when cross-examined, PW-2 Iftekhar Husain categorically stated that he did not take the injured to the hospital and had left the place of occurrence after 15 minutes. PW-3 Arshad Ali similarly stated that he did not take the injured to the hospital and had left for his village Dariyagarh.

The Court found these contradictions on a material point — namely, who accompanied the deceased to the hospital — to be irreconcilable and deeply damaging to the prosecution case. The Court also noted that the deceased had been admitted to the hospital by his father as an accidental case, and the hospital's communication to police described it as such — raising the pointed question: if two eyewitnesses had genuinely seen a deliberate tractor-murder and had even informed the first informant about it, why would the injured be admitted as an accident case at all?

On the Possibility of False Implication

The defence had placed before the Court a backdrop of bitter family enmity. The accused disclosed in their Section 313 CrPC statements that the father of first informant Mohammad Yusuf had been murdered in 1995, and that Mohammad Yusuf had subsequently ousted one of his nephews from the house and usurped approximately 70 bighas of land belonging to the deceased and his brother through a forged and unregistered Will. The Court held that in light of all the evidence — the accidental hospital record, the unexplained 49-hour delay, and the material contradictions among prosecution witnesses — "the possibility of the present appellants being falsely implicated on account of previous enmity cannot be ruled out" and that the appellants were entitled to the benefit of doubt.

The Allahabad High Court set aside the conviction and life imprisonment imposed by the Sessions Judge, Rampur and acquitted all three appellants of all charges. Appellants Irfan and Saleem, who were on bail, had their bail bonds cancelled and sureties discharged. Appellant Faeem, who had remained in jail, was directed to be released forthwith unless required in any other case. The judgment is a significant reminder that a prosecution built on an unexplained 49-hour delay, hospital records contradicting the homicide theory, and eyewitness accounts riddled with material contradictions cannot sustain a conviction for murder regardless of the gravity of the charge.

Date of Decision: March 18, 2026