Where Medical Evidence Creates Reasonable Doubt, Benefit Must Go To The Accused: Allahabad High Court Sets Aside Murder Conviction

"Medical Evidence Suggests Possibility of Accidental Death – Not Homicide", In a powerful reaffirmation of the primacy of forensic truth in criminal trials, the Allahabad High Court on 6th February 2026 overturned the conviction of two men accused of kidnapping and murdering their relative, observing that the medical evidence clearly left room for accidental death and did not establish murder beyond doubt. Division Bench of Justice Siddharth and Justice Jai Krishna Upadhyay held that “the cause of death remains inconclusive, and where death itself is not proved to be homicidal, conviction under Section 302 IPC cannot be sustained.”

This 34-year-old prosecution finally collapsed under the weight of its own speculative inferences, with the Court stating categorically that “conjecture and suspicion cannot take the place of legally admissible proof.”

“The injuries could have resulted from a fall from a moving train”: Court highlights contradiction between prosecution’s narrative and medical evidence

The High Court’s reasoning hinged heavily on the post-mortem findings of Dr. M. S. Ahlawat, who conducted the autopsy on the deceased Chandraprakash. He clearly stated before the Court that “the possibility of railway accident cannot be ruled out”, a conclusion that fundamentally undermined the prosecution’s theory of intentional homicide.

The Court noted that the doctor’s report had not identified any external injuries that would be consistent with assault or homicidal violence. On the contrary, the injuries were internal cranial fractures—typical of trauma suffered in railway accidents. The Bench observed, “Where the medical evidence does not support the charge of murder, but rather suggests a plausible alternative explanation such as an accident, the Court must not jump to conclusions.”

This aspect of the case became even more critical in light of the fact that the prosecution had no eyewitnesses to the crime, no murder weapon, and no forensic link tying the accused to the death. The entire case, the Court noted, “rested on the shifting sands of conjecture and incomplete circumstantial evidence.”

“Cause of death must be certain – not speculative”: High Court says prosecution failed to prove even that a murder took place

In its sharply worded judgment, the Court reminded that the starting point of any murder conviction must be the proof of homicidal death. If that foundation itself is shaky, the entire structure of the case collapses. As the Court held:

“It is not enough to allege that the accused were last seen with the deceased, or that there was some past dispute. The prosecution must first establish, with medical clarity, that the deceased died by human agency and not by accident.”

This principle, the Court emphasized, is deeply rooted in constitutional criminal jurisprudence: “the burden to prove guilt never shifts; the prosecution must establish every element of the offence beyond reasonable doubt.”

In a case that lay buried for decades under doubtful testimony and flawed assumptions, the Allahabad High Court has now unearthed and reaffirmed the true standard of criminal justice. In Criminal Appeal No. 4445 of 2005, the Court was dealing with the conviction of Anoop Singh and Ram Kumar—relatives of the deceased—who had been sentenced to life imprisonment for allegedly kidnapping and murdering Chandraprakash in February 1992. The conviction rested entirely on circumstantial evidence and the so-called “last seen” theory, with no direct proof of either the kidnapping or the murder.

What changed the trajectory of the appeal was the Court’s razor-sharp focus on the post-mortem evidence, which the trial court had ignored. The judgment was not just a rejection of weak prosecution, but a legal reiteration that medical science cannot be overruled by prosecutorial storytelling.

“Suspicion Cannot Take the Place of Proof”: High Court finds failure in establishing even the cause of death

The Court recorded with concern that the prosecution had failed to answer the most basic question: how did the deceased die?

The post-mortem was conducted two days after the body was found, and the doctor’s report clearly stated that death “could have occurred at any time on 09.02.1992”, and the injuries were consistent with a fall from a moving train. There was no evidence of strangulation, stabbing, or any other homicidal means. The Court remarked:

“Suspicion, however strong, cannot be elevated to the level of proof. The trial court ignored the expert’s opinion and proceeded to convict based on assumptions alone.”

It also noted that even the timeline advanced by the prosecution was riddled with uncertainties. The deceased was last seen with the accused on 07.02.1992, but his body was recovered on 09.02.1992. The significant time gap raised the possibility of third-party involvement or an accident, making the last-seen theory irrelevant. In that context, the Court held:

“The medical evidence does not just fail to support the prosecution—it directly weakens it.”

Conviction Set Aside, Acquittal Ordered

After critically examining the record, the High Court allowed the appeal, set aside the conviction, and ordered the immediate acquittal of Anoop Singh and Ram Kumar. The judgment stated:

“There is a deep chasm between ‘may be true’ and ‘must be true.’ The prosecution’s case never crossed that bridge.”

The Court ordered that their bail bonds be cancelled and sureties discharged, finally closing a case that had lingered for over three decades.

In doing so, the Bench once again emphasized the sacrosanct principle of the criminal trial: “Every accused is presumed innocent unless proven guilty—and that proof must be firm, not flimsy.”

Date of Decision: 6 February 2026