Conviction Under Sections 302/34 and 201/34 IPC Affirmed Based on Ocular, Scientific and CCTV Evidence Despite Absence of Motive
In a landmark judgment dated July 14, 2026, the Jharkhand High Court (Division Bench comprising Justices Rongon Mukhopadhyay and Pradeep Kumar Srivastava) upheld the conviction and life imprisonment sentences of Lakhan Kumar Verma and Rahul Kumar Verma for the murder of Uttam Anand, Additional District & Sessions Judge (ADJ), Dhanbad. The appellants were found guilty under Sections 302/34 (murder by common intention) and 201/34 (causing disappearance of evidence) of the Indian Penal Code.
The case arose from the shocking incident on the early morning of July 28, 2021, when Judge Uttam Anand was deliberately hit by a stolen auto-rickshaw near Randhir Verma Chowk, Dhanbad, while on his routine morning walk. The impact caused fatal head injuries, and despite emergency medical care, the judge succumbed to his injuries.
The prosecution’s case was built on a combination of eyewitness testimony, forensic evidence, and extensive CCTV footage. A key eyewitness, a cable man named Saddam Hussain, testified to seeing the auto-rickshaw swerve deliberately towards the judge and collide with him. The CCTV footage from multiple locations clearly showed the vehicle’s movement and the accused individuals’ presence. Scientific examination confirmed that the auto-rickshaw involved in the incident was stolen from Sugani Devi’s premises just hours before the murder. DNA evidence linked blood found on the vehicle to Lakhan Kumar Verma, who was driving the auto.
Forensic experts reconstructed the crime scene and concluded that the collision was intentional, with the auto-rickshaw veering at an angle of approximately 21 degrees towards the victim at a speed of 20-25 km/hr. Medical testimony established that the injuries to the judge’s head were sufficient to cause death in the ordinary course of nature, satisfying the legal requirement under Section 300 "Thirdly" IPC for murder.
The defence argued vehemently that no motive was established, and the incident was accidental, caused by a stone obstructing the auto’s path. The appellants denied any intention to cause harm and challenged the prosecution’s reliance on circumstantial evidence and forensic reports. They contended there was no proof of prior meeting of minds or conspiracy necessary to establish common intention under Section 34 IPC.
The High Court, however, rejected these arguments, holding that motive is not a sine qua non for conviction when direct and credible eyewitness and scientific evidence are available. Citing precedents like Chandan v. State (NCT of Delhi) and Virsa Singh v. State of Punjab, the Court emphasized that the intention to inflict bodily injury sufficient to cause death is the relevant test under Section 300 "Thirdly". The Court noted the appellant’s suspicious conduct post-incident, including fleeing and concealing the stolen vehicle, further indicating guilty knowledge.
Concluding that the appellants acted with common intention to commit the murder, the Court affirmed the trial court’s judgment, sentencing both to rigorous imprisonment for life without remission and imposing fines. The ruling sends a strong message underscoring that deliberate attacks on judicial officers will be met with the full rigor of law.
Bottom line:-
Conviction under Sections 302/34 and 201/34 IPC upheld on evidence of intentional and deliberate act of hitting the deceased with an auto rickshaw, despite absence of motive; common intention established through ocular, technical, and scientific evidence including CCTV footage and forensic reports.
Statutory provision(s): Sections 302, 201, 34, 300 IPC, Section 65B Evidence Act, Section 313 Cr.P.C.
This report encapsulates the key facts, legal issues, evidentiary highlights, and the Court’s reasoning in the judgment, providing a comprehensive understanding of this significant criminal case upheld by the Jharkhand High Court.
Lakhan Kumar Verma @ Lakhan Verma v. Union of India, (Jharkhand)(DB) : Law Finder Doc id # 2941319
