29 Years Later, Supreme Court Affirms Acquittal in Bihar ‘Honour Killings’ of Four Lovers

The Supreme Court on August 29, 2025 dismissed an appeal that challenged the acquittal of five accused in a case related to the alleged honour killings of two brothers and two sisters in Bihar in 1996. The Court upheld the Patna High Court’s 2013 judgment which confirmed the trial court’s decision to acquit all the accused for want of evidence.

A bench of Justices Sandeep Mehta and Joymalya Bagchi recorded that the prosecution could not produce any direct evidence in relation to the murders. The Court said the case was built only on circumstantial evidence, and even the theory of motive suggested by the prosecution was weak and insufficient to establish guilt.

The judges said they were of the firm opinion that the trial court was justified in acquitting the accused by giving them the benefit of doubt. The judgment of acquittal by the trial court had already been affirmed by the Patna High Court, and there was no reason to interfere with the concurrent findings.

The Court reiterated that the law on appeals against acquittal is settled. An appellate court should interfere only if the finding of acquittal is perverse on the face of the record or if no other view except that of guilt is possible after appreciating the evidence. Where two views are reasonably possible, one consistent with guilt and the other with innocence, the appellate court should refuse to interfere and allow the acquittal to stand.

The appellant, Nandeshwar Kumar, had challenged the Patna High Court’s judgment dated June 26, 2013 which upheld the acquittal recorded by the Additional Sessions Judge, Buxar, on December 18, 2012. Two of the accused, Rajendra Prasad Pandey and Yogendra Pandey, died during the proceedings, and the appeal against them abated.

According to the prosecution, the appellant lived with his two brothers in a rented house belonging to accused Rajendra Prasad Pandey. The brothers developed relationships with Pandey’s daughters, Renu Kumari and Rinki Kumari. The prosecution alleged that the landlord disapproved of these affairs, forced the tenants to vacate, and later conspired with his family to eliminate all four in an act of honour killing.

The prosecution alleged that the brothers of the appellant eloped with the daughters of the accused and that this gave rise to a grudge. The case was that the accused family eliminated all four to protect their family honour.

Two separate FIRs were registered. One FIR was lodged after the recovery of two unidentified male bodies on December 1, 1996 which were alleged to be those of Anjani Kumar Sharma alias Sablu and Yogesh Sharma alias Dablu, the brothers of the appellant. A separate FIR was registered after two unidentified female bodies were found, alleged to be the daughters of Rajendra Prasad Pandey. Since both cases had the common thread of love affairs, they were amalgamated and tried together.

The accused were arrested and charge sheeted between 2005 and 2006. Rajendra Prasad Pandey and Yogendra Pandey were arrested on July 2, 2005. Ravindra Kumar Pandey surrendered before the Chief Judicial Magistrate on June 5, 2006. Upendra Kumar Pandey was arrested on August 23, 2006. Pratap Pandey was arrested on September 5, 2006.

At the trial, the prosecution produced material to suggest motive but there were no eyewitnesses to the murders. The trial court found that even the identity of the dead bodies could not be established with certainty. The evidence failed to conclusively prove that the bodies were those of the brothers of the appellant and the daughters of the accused. The trial court also accepted the plea of alibi set up by the accused and found that the prosecution had not produced any direct or indirect evidence to connect them to the crime.

The trial court concluded that the case rested entirely on circumstantial evidence but the prosecution had not been able to prove a complete and unbroken chain of circumstances that pointed conclusively to guilt while ruling out every possibility of innocence. It acquitted all the accused by extending the benefit of doubt.

The High Court dismissed the complainant’s appeal and affirmed the acquittal. The Supreme Court has now upheld these findings, stating that after a threadbare examination of the record, no other view except the one taken by the trial court was possible. The appeal was dismissed.

Case Title: Nandeshwar Kumar v. Rajendra Prasad Pandey and Others

Judgment Date: August 29, 2025

Bench: Justices Sandeep Mehta and Joymalya Bagchi