Chandrasekhar Indi, identified as accused number sixteen in the Yogesh Goudar murder case, appeared before the Karnataka High Court on Wednesday, 1 July 2026, and submitted that the trial court’s judgment does not contain any explicit finding that he was a party to the criminal conspiracy alleged in the prosecution.
He stated that, despite the absence of such a finding, the trial court convicted him and imposed a sentence of life imprisonment under Section 120B of the Indian Penal Code, read with Section 302 IPC. The submission was made before a bench comprising Justice Mohammad Nawaz and Justice G.Basavaraja, which is presently hearing the matter.
The offence under Section 120B IPC punishes persons who are parties to a criminal conspiracy. For a conviction under this provision, the prosecution must prove, beyond reasonable doubt, that the accused agreed with one or more persons to commit an offence and that an act was done in pursuance of that agreement. The law requires the trial court to record a specific finding on the existence of the agreement and the accused’s participation therein.
Section 302 IPC provides for the punishment of murder. When a charge is framed under both Sections 120B and 302, the prosecution must establish that the accused was part of the conspiracy to commit murder and that the murder was carried out in furtherance of that conspiracy. The absence of a finding on the conspiracy element therefore raises a question of legal sustainability of the conviction under the combined charge.
Chandrasekhar Indi’s submission highlighted that the trial court’s order, while recording a conviction, did not articulate any reasoning or factual basis linking him to the alleged conspiracy. He argued that, in the absence of such a finding, the conviction cannot be sustained on appeal, as the appellate court cannot supply missing findings that are essential to the offence charged.
The bench listened to the submission and noted the issue raised. No interim order or observation regarding the sentence or the conviction was recorded in the proceedings reported. The matter remains sub judice before the High Court, and the parties are expected to address the legal question of whether the trial court’s judgment satisfies the statutory requirements for a conviction under Section 120B read with Section 302 IPC.
Legal practitioners observing the proceedings pointed out that appellate courts have consistently held that a conviction under Section 120B cannot be upheld if the trial court fails to record a finding on the existence of the conspiracy and the accused’s role therein. They emphasized that the burden of proving the conspiracy rests squarely on the prosecution, and the trial court must reflect its satisfaction on that point in its judgment.
The case stems from the killing of BJP leader Yogesh Goudar, for which several persons were charged. Chandrasekhar Indi, who is the uncle of former Congress MLA Vinay Kulkarni, is among those accused. The trial court had previously sentenced him to life imprisonment. The present submission seeks to challenge the legal foundation of that sentence on the ground of missing essential findings.
As the proceedings continue, the High Court will examine the trial record, assess whether any implicit finding can be inferred from the evidence appreciated by the trial court, and determine whether the conviction requires modification, remission, or a remand for fresh consideration of the conspiracy charge.