The Jharkhand High Court upheld the life imprisonment of two convicts in the 2021 murder of Additional District Judge Uttam Anand, holding that CCTV footage and forensic evidence conclusively proved the collision was deliberate

The Jharkhand High Court on July 14 upheld the conviction and life imprisonment of two men for the 2021 murder of Additional District and Sessions Judge Uttam Anand, describing the incident as an affront to the judiciary."

Dismissing the criminal appeals filed by Lakhan Kumar Verma and Rahul Kumar Verma, a Division Bench found that the prosecution had proved beyond a reasonable doubt that the appellants had intentionally rammed a stolen auto-rickshaw into the judge during his morning walk on July 28, 2021.
The Court affirmed their conviction under Sections 302/34 and 201/34 IPC.
The judge was killed in Dhanbad city of Jharkhand after being hit by an autorickshaw while he was on a morning walk on July 28, 2021.
The incident took place at Randhir Verma Chowk near Ganga Medical Hall under the Dhanbad police station area. The CCTV footage of the incident suggests that an autorickshaw hit the judge from behind and fled from the spot. The judge was rushed to the hospital, where he succumbed to his injuries.
In August 2021, the probe of the case was transferred to the Central Bureau of Investigation (CBI).
Exactly a year later, on July 28, 2022, a Special CBI Court in Dhanbad found the two accused guilty of murdering Judge Anand. Challenging the order and judgment of conviction, both the accused had moved the Jharkhand High Court.
What did the High Court observe?
A division bench comprising Justice Rongon Mukhopadhyay and Justice Pradeep Kumar Srivastava observed that the case was supported by an unbroken chain of ocular, documentary, scientific and technical evidence, including CCTV footage, forensic analysis, crime scene reconstruction, DNA evidence and expert testimony, leaving no scope to accept the defence that the collision was an accident.
Recounting the events of the morning, the Court noted that Judge Uttam Anand had left home for his routine walk when he was struck by an auto-rickshaw. Though some joggers and passersby saw him lying critically injured, many continued on their way.
The Court commended a passerby who arranged an e-rickshaw and rushed the unconscious judge to the hospital, as well as an Auxiliary Nurse Midwife who provided immediate assistance before he was admitted for emergency treatment. Despite doctors' efforts, the judge succumbed to his injuries.
The High Court observed that videos of the incident circulated widely on social media, generating public outrage as the attack was viewed as a direct assault on the judicial system, leading to the transfer of the investigation to the CBI.
CCTV footage established a deliberate hit
The Bench held that the CCTV footage formed the backbone of the prosecution's case. After personally viewing the footage in court, the court concluded that the auto-rickshaw, driven by the accused, Lakhan Kumar Verma, suddenly veered to the left, where Uttam Anand was walking, struck him, and then resumed its original course without any sign of panic or evasive manoeuvre.
According to the Court, the driver's (Lakhan Kumar Verma) conduct after the impact was inconsistent with an accidental collision. Rather than braking, swerving or reacting in shock, the vehicle continued normally, indicating a pre-meditated act.
The Court also relied upon the testimony of the sole eyewitness to the collision, who stated that he saw the auto deliberately move towards the left and hit the judge before continuing its journey. The witness further deposed that one occupant later got down from the vehicle while the other drove away.
Expert evidence ruled out the accident
The Division Bench attached significant weight to the evidence of forensic experts.
A behavioural and crime-scene profiling expert, after analysing multiple CCTV clips and photographs, concluded that someone had followed Uttam Anand in the auto-rickshaw and that the driver appeared to be "in good state of mind".
The expert opined that the incident "seems to be planned and intentional" and "does not appear to be an accident".
Another forensic expert testified that the driver remained in complete control of the vehicle throughout and made no attempt to turn away, brake or avoid the victim.
Instead, the auto specifically altered its course towards Uttam Anand before returning to its original path after impact. The expert concluded that the injuries were consistent with an intentional collision rather than an accident.
The Court further noted that a three-dimensional forensic reconstruction mathematically demonstrated the angle and trajectory of impact, corroborating the prosecution's version that the vehicle had been intentionally steered towards the judge.
Defence of accidental collision rejected
The principal defence advanced by the driver was that the auto had struck a stone lying on the road, causing it to veer uncontrollably towards the judge.
Rejecting this explanation as “fragile”, the High Court observed that repeated inspections of the scene by the investigating agencies never revealed any such stone. Nor did any forensic examination or CCTV footage indicate an obstruction that could have caused the vehicle to wobble or lose balance.
Instead, the footage showed smooth movement of the auto before a sudden deviation towards the victim, rendering the defence wholly unacceptable.
Theft of auto and conduct of accused showed common intention
The Court also relied upon evidence showing that the auto-rickshaw used in the offence had been stolen the previous night.
It found that both accused were travelling together in the stolen vehicle at the time of the incident and fled thereafter, later concealing the auto-rickshaw.
Their conduct after the offence, the Bench held, was relevant under Section 8 of the Evidence Act and demonstrated their common intention.
Further, DNA evidence, CCTV footage, mobile phone records, witness testimony and even admissions made by one of the appellants during his defence collectively established their presence in the offending vehicle.
Conviction for murder upheld
Rejecting the submission that a single impact could not amount to murder, the High Court held that the case squarely attracted Section 300 "Thirdly" IPC.
Referring to Virsa Singh v. State of Punjab, the Bench held that where an accused intentionally inflicts a bodily injury sufficient in the ordinary course of nature to cause death, the offence amounts to murder.
In the present case, the deliberate use of the auto-rickshaw to strike the judge on a vital part of his body satisfied that requirement, the Court said.
The Court also held that once direct ocular, scientific and documentary evidence established the offence, the absence of proof regarding motive became immaterial.
Accordingly, finding no infirmity in the trial court's appreciation of evidence, the Division Bench dismissed both appeals and affirmed the life sentences imposed on the convicts.
Case Title: Lakhan Kumar Verma And Anr v Union of India through CBI
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