Allahabad High Court Acquits 100-Year-Old After 42 Years In Murder Case

After more than four decades of pendency, the Allahabad High Court recently set aside the 1984 murder conviction of a 100-year-old man, holding that the prosecution failed to prove its case beyond reasonable doubt and that the criminal process itself had stretched into a form of punishment.

Allowing a criminal appeal filed in 1984, a division bench of Justices Chandra Dhari Singh and Sanjiv Kumar acquitted Dhani Ram alias Dhanaiyan, noting that such extraordinary delay, coupled with uninterrupted liberty on bail for decades, constituted a relevant and weighty consideration while fashioning relief.

The bench recorded that the appeal had remained pending since shortly after the conviction by the additional sessions judge, Hamirpur, in July 1984. Dhani Ram was enlarged on bail in August 1984 and continued to remain on bail throughout the pendency of the appeal. His co-accused and brother, Satti Din, died during the pendency of proceedings, leading to abatement of the appeal against him in 2018.

Court said that criminal proceedings that span generations cease to be merely a mechanism of accountability and begin to assume the character of punishment in themselves. It emphasised that anxiety, uncertainty and social consequences suffered over decades could not be ignored while assessing what justice ultimately demands.

“Delay of such magnitude is not a mere administrative lapse,” the bench said, adding that when the system itself fails to deliver finality within a reasonable time, courts are justified in adopting a tempered and humane approach.

Further, taking note of appellant's old age, the bench said, "Justice is not an abstraction divorced from human conditions," adding that the law cannot be oblivious to the reality that advancing age brings with its physical fragility, dependence, and a narrowing horizon of life.

"When a person stands before the court at the twilight of existence, the insistence on penal consequences, after decades of procedural delay, risks transforming justice into a ritual divorced from the purpose it intends," the bench stressed. 

Case background:

One Gunuwa was killed in August 1982 in Hamirpur district of Uttar Pradesh. An FIR was lodged by his brother Raja Bhaiya, who alleged that Gunuwa was shot dead by one Maiku, while Satti Din and Dhani Ram alias Dhanaiyan (the present appellant) exhorted him to kill. The prosecution claimed the three acted with common intention. Maiku absconded. 

After investigation, Satti Din and Dhani Ram were charge-sheeted and tried for murder under Section 302 of the Indian Penal Code (corresponding to Section 103 of the Bharatiya Nyaya Sanhita) read with Section 34 (corresponding to Section 3(5) of the BNS). In July 1984, the additional sessions judge, Hamirpur, convicted both and sentenced them to life imprisonment.

The accused were released on bail in August 1984 and filed an appeal before the high court the same year. During the pendency of the appeal, Satti Din died, leading to abatement of proceedings against him, while the appeal continued against Dhani Ram for over four decades.

Court's analysis:

On merits, the high court found the prosecution case riddled with contradictions and improbabilities. It pointed out inconsistencies regarding the preparation and timing of the FIR, discrepancies between eyewitness accounts and medical evidence, and serious doubts about the alleged role attributed to the appellant.

The bench also observed that the medical evidence did not support the prosecution version regarding the manner in which injuries were inflicted upon the victim. Court noted that the punctured wound allegedly caused by Satti Din could not be reconciled with the prosecution version of events and that the eyewitness's conduct did not inspire confidence.

Court also recorded that the motive was not established and that the possibility of false implication could not be ruled out, particularly in the backdrop of prior enmity involving other accused persons.

Court, therefore, concluded that prosecution failed to prove its case “beyond reasonable doubt” against the appellant.

Although court decided the case on merit, it emphasised that the extraordinary delay in disposal of criminal appeals, coupled with the advanced age of the accused and long periods of liberty on bail, constituted a relevant and weighty consideration while moulding relief.

Case Title: Satti Din and another vs. State of U.P.

Judgment Date: January 21, 2026

Bench: Justices Chandra Dhari Singh and Sanjiv Kumar