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Bhagwani v. State of Madhya Pradesh — Medical evidence in a circumstantial POCSO kidnapping-rape-murder case

Part of the Forensic Docket on Legal Desire Forensics — how a forensic technique fared under appellate scrutiny.

The facts

The case concerned the kidnapping, rape and murder of an 11-year-old girl, prosecuted under Sections 363, 366A, 364, 346, 376D, 376A, 302 and 201 of the Penal Code together with the Protection of Children from Sexual Offences Act, 2012.

The victim’s father, PW-2, had been with her in the evening; she then went missing and was found dead the next morning.

The appellant, along with a co-accused who has since died, was convicted and sentenced to death on the basis of circumstantial evidence.

On appeal, the Supreme Court examined the medical evidence bearing on the case as part of its review of the circumstantial chain, and the appeal was ultimately partly allowed.

Why this belongs in the Forensic Docket: A reminder that in circumstantial death-penalty cases, medical evidence must be examined as one link in the whole chain, and can itself be decisive to whether that chain is treated as complete and unbroken.

Case details

Citation [2022] 8 S.C.R. 1
Case number CRIMINAL APPEAL No. 101/2022
Court Indian Supreme Court
Decided 2022-01-18
Module Case Method Library

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

Explore more in the Forensic Docket or browse the full Forensics hub.

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Anuj Kumar
https://legaldesire.com/about-us/
Legal Desire Media and Insights is a leading legal news and insights platform founded in 2012 by Anuj Kumar, a lawyer, author and legal industry entrepreneur with 14 years in legal publishing. Our editorial team covers judgments, deals, law firm updates, careers and policy across India, the US, UK and Gulf. Coverage is editorially independent; sponsored posts are labeled Partner Content. Contact: legaldesire.com/contact