Introduction:

The Allahabad High Court, in Hareram Chaudhary v. State of Uttar Pradesh (2026 LiveLaw (AB) 325), reaffirmed the settled principle that the absence or weakness of motive cannot by itself discredit the prosecution’s case when the commission of the offence is established through reliable ocular evidence. A Division Bench comprising Justice Rajnish Kumar and Justice Zafeer Ahmad dismissed the criminal appeal filed by the appellant and upheld his conviction and life sentence for the murder of the head secretary of an ashram in Barabanki.

According to the prosecution, the incident occurred during the intervening night of 15 and 16 May 2015 at Purshottam Dham Ashram. The deceased, Thakur Ram Sahai Singh, was sleeping in the open on the ashram premises when the appellant allegedly shot him in the head at around 2:00 a.m. Eyewitnesses present nearby stated that the appellant’s associates encouraged him to kill the deceased while threatening others from intervening. Following investigation, the trial court convicted the appellant under Section 302 of the Indian Penal Code and Section 3/25 of the Arms Act, sentencing him to life imprisonment. Aggrieved by the conviction, the appellant approached the High Court.

Arguments of the Parties:

The appellant challenged the conviction primarily on the ground that the First Information Report was lodged after an unexplained delay of nearly eleven hours, creating serious doubts about the prosecution’s version. It was also argued that several persons initially named as co-accused were subsequently dropped during investigation, thereby affecting the credibility of the prosecution case. The appellant further submitted that the prosecution had failed to establish any convincing motive for the alleged murder and had not proved the charges beyond reasonable doubt.

The State defended the judgment of the trial court by contending that the delay in lodging the FIR was fully explained by the extraordinary circumstances prevailing after the murder. The brutal killing of the ashram head had created fear and panic among the residents, while the assailants had threatened anyone who attempted to report the crime. The prosecution also relied upon the consistent testimonies of eyewitnesses, the lawful recovery of the country-made pistol used in the offence under Section 27 of the Evidence Act, and other corroborative evidence to establish the appellant’s guilt beyond reasonable doubt.

Court’s Judgment:

The High Court dismissed the appeal and affirmed the conviction and life sentence awarded by the trial court. Addressing the delay in registration of the FIR, the Court held that the surrounding circumstances adequately explained the delay. Considering the atmosphere of fear and intimidation created by the assailants immediately after the incident, it was natural that the complaint was lodged the following morning. The Court reiterated that a reasonably explained delay in filing the FIR cannot, by itself, be a ground to discard an otherwise reliable prosecution case.

The Bench further held that motive, though relevant in criminal cases, assumes lesser significance where the prosecution produces trustworthy eyewitness testimony. The Court observed that motive often remains within the exclusive knowledge of the accused and may not always be capable of direct proof. Referring to the Supreme Court’s decision in Subhash Aggarwal v. State of NCT of Delhi (2025 LiveLaw (SC) 443), the Court reiterated that failure to prove motive is not fatal where convincing evidence establishes the guilt of the accused beyond reasonable doubt.

In the present case, the Court noted that evidence suggested hostility between the appellant and the deceased following the appellant’s expulsion from the ashram. Moreover, the appellant himself admitted the existence of enmity in his statement recorded under Section 313 of the Code of Criminal Procedure, thereby reinforcing the prosecution’s case regarding motive.

The Court also upheld the recovery of the 315-bore country-made pistol, observing that it was legally recovered pursuant to the appellant’s disclosure statement under Section 27 of the Evidence Act. Most importantly, the Court found the testimonies of the eyewitnesses to be consistent, natural and mutually corroborative regarding the time, place, manner of occurrence and identity of the accused. Their cross-examination failed to expose any material contradiction capable of discrediting their evidence.

Holding that the prosecution had successfully proved the appellant’s guilt beyond reasonable doubt, the High Court concluded that the trial court’s judgment suffered from no legal infirmity or perversity. Consequently, the conviction under Section 302 IPC and Section 3/25 of the Arms Act, along with the sentence of life imprisonment, was affirmed and the appeal was dismissed.