Concurrent Acquittal Upheld: Supreme Court Declines to Interfere in Murder Case with Mismatch Between Ocular and Medical Evidence

Case Snapshot

• Case Name: Sanjay Kumar v. State of Bihar & Anr.

• Citation: 2026 INSC 735

• Bench: Justice Nongmeikapam Kotiswar Singh & Justice Sanjay Karol

• Date of Judgment: July 22, 2026

• Area of Law: Criminal Law, Acquittal, Appeal, Evidence

Judgment in Brief

The Supreme Court dismissed the appeal and upheld the concurrent acquittal of the respondent-accused in a murder case. The Court reaffirmed the limited scope of interference with concurrent findings of acquittal, holding that such interference is warranted only when the acquittal is perverse, manifestly illegal, or wholly unsustainable. The Court found that the prosecution case suffered from several infirmities, including a mismatch between the ocular version and the medical evidence, hostility and non-examination of independent witnesses, reliance on interested witnesses whose presence was doubtful, and unexplained delays in investigation. Even if the chin injury attributed to the respondent appeared to match the medical evidence, the overall prosecution case did not cross the threshold of proof beyond reasonable doubt. The benefit of doubt was rightly granted to the accused.

Relevant Facts

• On October 11, 1998, the deceased, along with his son (the appellant), the informant, and others, was returning from a market when the respondent and other accused allegedly intercepted them.

• The respondent, armed with a rifle, is alleged to have fired at the deceased, the shot striking him on the right side of his chin/beard. Three other accused also allegedly fired at the deceased.

• The FIR alleged four gunshot injuries: one on the forehead, one on the temple, one on the back/head, and one on the chin.

• The deceased succumbed to injuries on the spot. The FIR was registered the next day.

• The Trial Cour

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