Supreme Court Upholds Conviction in 2012 Kerala Rape and Murder Case | Highlights Guidelines for Circumstantial Evidence

Payal Singh

11 months ago

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The Supreme Court of India upheld the conviction in a rape and murder case from Kerala, emphasizing the need for rigorous assessment of circumstantial evidence. The accused, linked through forensic evidence, received a death sentence and additional imprisonment. The Court established clear guidelines for evaluating circumstantial evidence and dismissed appeals regarding investigation flaws.

New Delhi: The Supreme Court of India upheld the conviction in a heinous rape and murder case from Kerala, emphasizing the critical importance of thorough evaluation of circumstantial evidence in criminal cases. This judgment sets a precedent for trial and appellate courts to adhere to rigorous standards when assessing cases built on circumstantial evidence.

The case dates back to April 4, 2012, when a third-grade student went missing on her way to the Madrassa in a Kerala village. A frantic search ended tragically with the discovery of her body in the bathroom of the suspect’s house later that evening. Forensic evidence, including DNA analysis, directly linked the accused to the crime.

The accused was convicted by the Sessions Court for offenses under Sections 302 (murder) and 376 (rape) of the Indian Penal Code (IPC) and Section 23 of the Juvenile Justice (Care and Protection) Act, 2000. He received a death sentence for murder and seven years of rigorous imprisonment for rape. This sentence was confirmed by the Kerala High Court in February 2018.

However, the Supreme Court stayed the execution in 2018, and the case was pursued posthumously by the accused’s legal heirs after his death in custody in January 2024.

The defense raised several key issues:

Chain of Circumstantial Evidence: The defense argued that the prosecution failed to establish an unbroken chain linking the accused to the crime.
Forensic Evidence: The admissibility and reliability of DNA and serological reports were challenged.
Investigation Flaws: Alleged lapses, including contamination of evidence and improper storage of biological samples, were highlighted.
Fair Trial Concerns: The accused contended that crucial evidence was not adequately put to him during his examination under Section 313 of the CrPC.

A Bench comprising Justice B.R. Gavai, Justice K.V. Viswanathan, and Justice Sandeep Mehta dismissed the appeals, finding the prosecution’s evidence credible and the chain of circumstances complete. Citing the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra (1984), the Court reiterated the “five golden principles” for circumstantial evidence:

All circumstances must be fully established.
Established facts must exclusively point to the accused’s guilt.
Circumstances must be conclusive.
No plausible alternative hypothesis of innocence should exist.
The chain of evidence must be unbroken and leave no reasonable doubt.

The Court stated:

“The judgment must comprehensively elucidate the rationale for accepting or rejecting specific pieces of evidence, demonstrating how the conclusion was logically derived from the evidence.”

Key Evidence Considered

DNA Analysis: Seminal stains on the victim’s clothing and swab matched the accused. Bloodstains in the accused’s house matched the victim’s blood type.
Witness Testimonies: The victim was last seen heading to the Madrassa with the accused’s daughter, and neighbors reported suspicious behavior by the accused.
Postmortem Report: It revealed 37 ante-mortem injuries and evidence of forcible sexual assault. The cause of death was strangulation.

Guidelines for Circumstantial Evidence

The Supreme Court criticized lower courts for inadequate reasoning and provided detailed guidelines for evaluating circumstantial evidence, including:

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