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Ranjeet Kumar Ram @ Ranjeet Kumar Das v. State of Bihar

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1831 of 2011)Decided 15 May 2015
Criminal Appeal No. 1831 of 2011
Justice T.S. Thakur · Justice R. Banumathi

Background

A five-year-old boy, Vicky, was lured away with chocolates by two men and never returned; his father later received ransom calls demanding money, eventually paying Rs.1,05,000 but his son was not released and was found to have been murdered. Four accused, Ranjeet Kumar Ram, Sanjay Mahto, Chintoo Singh, and Birendra Bhagat, were tried; the trial court and the Patna High Court convicted all of them for kidnapping and murder, and a death sentence awarded to Chintoo Singh was commuted to life imprisonment by the High Court. All four approached the Supreme Court by separate appeals.

Decision Breakdown

The Supreme Court examined the circumstantial evidence against each accused separately. It upheld the convictions of Ranjeet Kumar Ram, Chintoo Singh and Birendra Bhagat, finding strong links such as recovery of a ransom currency note from Ranjeet's house and his suspicious conduct and persistent pressure on the victim's father to pay ransom, which together proved shared common intention to kidnap and kill. However, regarding Sanjay Mahto, the Court held that mere suspicion, even strong suspicion, such as having accompanied the father to deliver the ransom, cannot substitute for proof, and since no recovery or other incriminating evidence tied him to the crime, his conviction could not stand. Accordingly, the appeals of Ranjeet Kumar Ram, Chintoo Singh, and Birendra Bhagat were dismissed, while Sanjay Mahto's appeal was allowed and he was acquitted and ordered released.

Lesson Learnt

In criminal cases built on circumstantial evidence, each accused's culpability must be established independently through concrete links (such as recovered property or proven conduct), being merely present or associated with the principal accused, however suspicious it looks, is not enough to sustain a conviction; suspicion can never substitute for proof beyond reasonable doubt.

Official source (sci.gov.in)View Judgment (PDF)

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