The Supreme Court has upheld the conviction and life sentence of 4 men in connection with the murder of a man named Balkishan in Madhya Pradesh, ruling that minor procedural lapses in the investigation do not invalidate an otherwise credible prosecution case.
A bench comprising Justices Pankaj Mithal and S. V. N. Bhatti dismissed a batch of criminal appeals filed by the accused persons challenging their conviction. The Court affirmed the judgments of the trial court and the High Court which had sentenced them to life imprisonment.
Background of the Case
The case concerns the murder of Balkishan, who was chased and shot dead by a group of accused persons. The appeals were filed by four convicts—Dablu (A-1), Kamlesh (A-2), Pratap @ Pratap Narayan (A-5), and Vinod @ Ajay (A-4).
According to the prosecution, the accused chased the deceased from a bus stand to his house. During the chase, multiple shots were fired, resulting in Balkishan’s death. The prosecution relied on eyewitness testimony and circumstantial evidence to establish that the accused acted as an unlawful assembly with a common object to kill the victim.
The trial court convicted the accused and sentenced them to life imprisonment. The High Court subsequently upheld the conviction, leading the accused to approach the Supreme Court.
Table of Contents
Main Legal Issue
The principal legal question before the Court was whether alleged procedural irregularities—particularly non-compliance with Section 157 of the Code of Criminal Procedure (CrPC) regarding the forwarding of the FIR report—were sufficient to undermine the prosecution’s case.
The appellants argued that such lapses weakened the credibility of the investigation and should result in acquittal.
Supreme Court’s Observations
The Supreme Court rejected the contention that procedural irregularities in compliance with Section 157 CrPC automatically invalidate the prosecution case. The Court observed that the alleged lapse had not been properly substantiated by summoning the relevant records from the Magistrate’s court.
The bench held that even if such a procedural irregularity had occurred, it would not be fatal to the prosecution when the substantive evidence clearly establishes guilt.
The Court further noted that the evidence demonstrated that the accused chased the deceased from the bus stand to his residence and collectively participated in the attack. The fact that some witnesses did not see every accused firing shots or fleeing from the scene did not undermine the prosecution narrative.
Application of Section 149 IPC
The Court emphasized the applicability of Section 149 of the Indian Penal Code, which holds every member of an unlawful assembly liable for an offence committed in pursuit of the assembly’s common object.
The bench held that the collective actions of the accused—chasing the victim and participating in the attack—were sufficient to attract liability under Section 149 IPC. Consequently, each accused could be held responsible for the murder even if the specific act of firing the fatal shot was not attributed to all of them.
Verdict
After examining the evidence and the reasoning of the lower courts, the Supreme Court concluded that the findings of conviction did not suffer from any illegality or perversity.
“The judgments and orders passed by the two courts below do not suffer from any illegality which may require to be disturbed,” the Court held while dismissing the appeals.
Direction to Surrender
The Court also noted that the appellants were currently on bail. It directed them to surrender immediately before the authorities to serve the remaining portion of their life sentence.
Case Details
Case Title: Dablu Etc. Versus State of MP
Citation: JURISHOUR-315-SC-2026
Case No.: Criminal Appeal Nos. 1819-1821 OF 2011
Date: 11/03/2026
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