The Supreme Court on 7 April 2026 set aside the conviction and life sentence of Gautam Satnami @ Gautam Deshlahre under Section 302 IPC, acquitting him of the charge of murdering Dhumman @ Surjeet Bhattacharya in village Dhourabhata, Chhattisgarh on the night of 14 January 2011. A bench comprising Justices Prashant Kumar Mishra and Vipul M. Pancholi allowed the criminal appeal arising out of SLP (Crl.) No. 11080 of 2022 and directed that the appellant, who was already on bail pursuant to the Court’s order dated 22 April 2025, shall stand discharged from his bail bonds.
The prosecution case rested entirely on circumstantial evidence with no direct eyewitness to the crime. It was alleged that the appellant, harbouring enmity with the deceased over a past quarrel, went to his house at night armed with an axe, inflicted multiple incised injuries causing instantaneous death due to shock and haemorrhage, and fled. The Trial Court convicted the appellant while acquitting co-accused Dwarika Jangde on identical recovery evidence. The High Court affirmed the conviction.
The Supreme Court, after re-appreciating the entire evidence, held that the prosecution failed to prove the charge beyond reasonable doubt. The Court observed that the so-called “last-seen” testimony of Raja Ram Deshlahre (PW-4) was unreliable. Identification at night was doubtful in the absence of street lights and electricity in the deceased’s house; the witness was interested due to prior hostility and family ties with other villagers who had enmity with the appellant; and his statement under Section 161 CrPC was recorded after a delay of one month.
On the recovery of the blood-stained axe and clothes from the appellant’s house pursuant to disclosure statements under Section 27 of the Evidence Act, the Court noted serious infirmities. The disclosure statements of both accused were substantially identical and verbatim in parts. Witnesses to the disclosures and seizure memos either turned hostile or admitted that signatures were not obtained contemporaneously at the place of recovery. Forensic Science Laboratory reports confirmed human blood but failed to determine blood groups, gave no conclusive opinion that the hair on the axe belonged to the deceased, and established no definitive link between the recovered axe and the injuries. The seized weapons were never shown to the doctor for an opinion on whether they could have caused the fatal injuries. The Court held that such recoveries, riddled with procedural lapses and lacking corroboration, remained legally tenuous.
The alleged recovery of the appellant’s driving licence from the scene of crime was also found doubtful. It was not mentioned in the charge-sheet, was produced later, and the seizure witness could not even identify it or confirm its ownership at the relevant time.
The Court reiterated the five golden principles laid down in Sharad Birdhi Chand Sarda v. State of Maharashtra and held that the circumstantial evidence did not form a complete and unbroken chain pointing unerringly to the guilt of the appellant. The acquittal of co-accused Dwarika Jangde on similar evidence further strengthened the case for extending the benefit of doubt. Motive, though alleged, was found weak and insufficient to sustain conviction in the absence of other reliable circumstances.
Accordingly, the Supreme Court held that the appellant, like the co-accused, deserved the benefit of doubt. The judgments of the Trial Court and the High Court were set aside insofar as they related to the appellant, who was acquitted of the charge under Section 302 IPC.
Case Title: Gautam Satnami v. State of Chhattisgarh
Criminal Appeal No.: 1782 of 2026 (arising out of SLP (Crl.) No. 11080 of 2022)
Coram: Justices Prashant Kumar Mishra and Vipul M. Pancholi
Click HERE for full Judgment
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