Chhattisgarh High Court Confirms Life Sentence in Rape and Murder of Minor: DNA Profiling Held as Conclusive Evidence
Case Overview
The Chhattisgarh High Court at Bilaspur delivered a significant ruling in CRA No. 614 of 2023 (Neutral Citation: 2026:CGHC:16354-DB), pronounced on 09.04.2026, affirming the conviction and life imprisonment awarded to an accused for the brutal rape and murder of a nine-year-old girl. The judgment was authored by Hon'ble Chief Justice Ramesh Sinha on behalf of a Division Bench also comprising Hon'ble Justice Ravindra Kumar Agrawal.
The judgment carries immense precedential value, particularly in its declaration that scientific evidence such as DNA profiling and reliable medical reports can independently sustain a conviction — even in circumstances where the "last seen together" theory has not been conclusively established.
Key Legal Principle Laid Down: "The heinous offence of sexual assault culminating in murder, established through cogent medical evidence and reliable DNA profiling, conclusively proves the guilt of the appellant beyond reasonable doubt, fully satisfying the standard of proof; if such evidence inspires the Court's confidence, it can serve as the sole basis for conviction."
Background and Procedural History
How the Appeal Came to Be Heard
The criminal appeal was originally listed for hearing on I.A. No. 01 — an application seeking suspension of sentence and bail for the appellant. However, with the mutual agreement of counsel on both sides, the Division Bench proceeded to hear and decide the appeal on merits, given that the appellant had been in custody since 19.01.2020. Consequently, I.A. No. 01 was disposed of accordingly.
The Impugned Judgment
The appeal was preferred under Section 374(2) of the Code of Criminal Procedure, 1973 (Cr.P.C.), challenging the judgment of conviction and sentence dated 22.12.2022 passed by the Additional Sessions Judge (F.T.C.), South Bastar Dantewada (C.G.) in Special Case (POCSO) No. 10/2020.
The Trial Court had convicted the appellant for the following offences and imposed the corresponding sentences:
| Offence | Sentence |
|---|---|
Section 302 of the Indian Penal Code, 1860 (IPC) |
Life imprisonment + fine of Rs. 2,000/- (default: one year additional rigorous imprisonment) |
Section 376(AB) of the IPC |
Life imprisonment till natural death + fine of Rs. 2,000/- (default: one year additional rigorous imprisonment) |
Section 6 of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act) |
Life imprisonment till natural death |
Both sentences were ordered to run concurrently.
The Prosecution's Case
The Incident
On 13.01.2020, the deceased minor girl set out toward the local market. Her grandmother (PW-08) attempted to stop her from going alone. At that moment, the accused intervened and offered to accompany the child to the market and ensure her safe return. Trusting his assurance, the family permitted the girl to go with him. She never returned. Subsequently, information was received about the recovery of a dead body, which was identified by the victim's relatives — including PW-07 and PW-13 — as that of the missing child.
Analysis of Evidence by the High Court
1. Identification of the Deceased
The Court examined the chain of evidence establishing the identity of the recovered body with meticulous care, particularly since the entire case rested on circumstantial evidence.