Brief Background
The case of Govind Mandavi v. State of Chhattisgarh (SLP (Crl) No. 13533 of 2025) dated 08.12.2025 arose from a brutal murder in April 2021 in Kanker district, Chhattisgarh. The deceased, Bivan Hidko, was attacked late at night while sleeping in a farm hut with his wife, Sukmai Hidko (PW-2). According to the initial complaint lodged by his father, Heeralal Hidko (PW-1), two masked men entered the hut, took Bivan away, and assaulted him with a sharp weapon. Bivan was later found dead in a pool of blood.

The police registered an FIR against unknown assailants. Four days later, Sukmai claimed that during the assault one of the assailants’ masks slipped, allowing her to identify him as Govind Mandavi/Appellant. It is important note that Sukmai in her initial version had only mentioned about two masked men. Govind/Appellant was arrested along with two co-accused, and recoveries of blood-stained articles were made. The trial court convicted all three accused under Sections 302/34 and 460 IPC, sentencing Govind/Appellant and one co-accused to life imprisonment.

On appeal, the High Court acquitted the two co-accused but upheld Appellant/Govind’s conviction, relying on Sukmai’s testimony, her identification of Govind in a Test Identification Parade and forensic evidence showing human blood on articles recovered from him. Govind/Appellant then approached the Supreme Court, challenging the conviction.

Legal Submissions By The Parties

Appellant
Appellant argued that Govind was never named in the FIR or the complaint, which only referred to “unknown masked men,” and this omission was a serious flaw undermining the prosecution’s case. They contended that Sukmai’s later claim of identifying Govind was a material improvement introduced after an unexplained delay of several days, making it unreliable, particularly in light of the admitted family enmity. The defence emphasized that Sukmai was conscious enough to narrate details immediately after the incident, yet failed to mention Govind at that stage, rendering her subsequent identification suspect. The prosecution’s explanation that she was ill and traumatized was dismissed as implausible, especially since no medical evidence supported it. The defence further questioned the necessity of the Test Identification Parade, given that Govind was already known to Sukmai, and criticized the forensic evidence as inconclusive because the blood group on the recovered articles was neither established nor matched to the deceased.

Respondent
The State defended the conviction by asserting that Sukmai’s delayed identification of Govind was natural, given the trauma she experienced after witnessing her husband’s murder. It was argued that her testimony, reinforced by her identification of Govind both in the Test Identification Parade and in court, was reliable and sufficient to sustain the conviction. The State further emphasized that Govind had a clear motive, being the brother of Binda Bai (deceased’s second wife) with frequent quarrels between the two wives and family disputes providing strong grounds for hostility. Additionally, the recoveries of blood-stained articles from Govind were said to corroborate Sukmai’s account, even though the blood group could not be conclusively determined. On this basis, the State urged that the concurrent findings of guilt recorded by the trial court and affirmed by the High Court should not be disturbed.

Court’s Decision
The Supreme Court carefully examined the evidence and submissions. It noted that the FIR and complaint, based on Sukmai’s immediate version, mentioned only “unknown masked men.” Govind’s name was absent from the earliest accounts, which carried the evidentiary weight.

The Court found Sukmai’s later identification of Govind problematic. Her claim that his mask slipped and she recognized him was introduced after a delay, raising doubts about its reliability. The Court emphasized that in cases of prior enmity, such improvements must be scrutinized with caution to avoid false implication. The Court also observed that the forensic evidence was inconclusive. While human blood was detected on Govind’s seized articles, the blood group was indeterminate, preventing a direct link to the deceased.

Regarding the TIP, the Court agreed with the defence that it was unnecessary since Govind was already known to Sukmai. Conducting a TIP in such circumstances did not add credibility.

Ultimately, the Court held that the prosecution had failed to establish Govind’s guilt beyond reasonable doubt. The omission of his name in the FIR, the delayed and inconsistent identification, the admitted family enmity, and inconclusive forensic evidence together created serious doubts. Applying the principle that benefit of doubt must go to the accused, the Supreme Court set aside Govind’s conviction and ordered his acquittal.

Conclusion
The Supreme Court’s ruling in Govind Mandavi v. State of Chhattisgarh (SLP (Crl) No. 13533 of 2025) underscores the importance of consistency and reliability in criminal prosecutions. FIRs and earliest versions of events carry critical evidentiary value, and omissions therein cannot be lightly brushed aside. The judgment also highlights the limited probative value of inconclusive forensic evidence and the need for careful scrutiny of TIPs when the accused is already known to the witness.

By - C. George Thomas and Gurkaranbir Singh