Supreme Court Upholds Conviction in Custodial Death Case: Shanmugam vs. State (2021)

Date of the Judgment: April 6, 2021

Citation: (2021) INSC 177

Judges: Ashok Bhushan, J., S. Abdul Nazeer, J., Hemant Gupta, J.

The Supreme Court of India, in a recent judgment, addressed a critical question regarding the conviction of an accused based on circumstantial evidence in a custodial death case. The core issue was whether the prosecution had successfully established a complete chain of events to prove the guilt of the accused beyond a reasonable doubt. The judgment was delivered by a three-judge bench comprising Justices Ashok Bhushan, S. Abdul Nazeer, and Hemant Gupta. The majority opinion was authored by Justice S. Abdul Nazeer.

Case Background

On September 9, 2005, the appellant, Shanmugam, was arrested by PW-1, a Sub-Inspector of Police, for offences under the Copyright Act, 1957. He was taken to the Video Piracy Cell office at 11:30 p.m. The deceased, Head Constable Kaliappan, was also present in the same room. The next day, on September 10, 2005, at approximately 2:00 a.m., the appellant allegedly attacked the deceased with an iron stool, resulting in his death. The appellant was apprehended while attempting to escape by PW-1 and PW-2, another Head Constable.

The prosecution’s case rested on the fact that the appellant and the deceased were alone in the office when the incident occurred, and the appellant failed to provide a satisfactory explanation for the constable’s death. The appellant was charged under Section 302 of the Indian Penal Code (IPC) for murder and Sections 224 read with 511 of the IPC for attempting to escape from custody.

Timeline

Course of Proceedings

The Additional Sessions Judge, Fast Track Court No. II, Coimbatore, convicted the appellant under Section 302 of the Indian Penal Code (IPC) for murder and Sections 224 read with 511 of the IPC for attempting to escape from custody. The appellant was sentenced to life imprisonment and a fine. Aggrieved, the appellant filed a criminal appeal before the High Court of Judicature at Madras, which upheld the conviction and dismissed the appeal. Subsequently, the appellant approached the Supreme Court by way of a Special Leave Petition.

Legal Framework

The case primarily revolves around the interpretation and application of the following legal provisions:

• Section 302 of the Indian Penal Code (IPC): This section defines the punishment for murder. It states, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
• Section 224 read with Section 511 of the Indian Penal Code (IPC): Section 224 deals with resistance or obstruction by a person to his lawful apprehension. Section 511 deals with punishment for attempting to commit offences punishable with imprisonment for life or other imprisonment.
• Copyright Act, 1957: The appellant was initially arrested for offences punishable under Sections 51 read with 63, 52 A read with 68-A and 65 of the Copyright Act, 1957.

Arguments

Appellant’s Arguments:

• The appellant’s counsel argued that the prosecution’s case was based on circumstantial evidence, and there was no direct evidence to prove the appellant’s guilt beyond a reasonable doubt.
• It was contended that the prosecution failed to establish a complete chain of circumstances to link the appellant to the crime.
• The defense argued that the conviction was based on assumptions and not on concrete evidence.

State’s Arguments:

• The State’s counsel argued that the court should consider the circumstances in a holistic manner and not in isolation.
• The prosecution contended that the chain of events was completely proven, establishing the appellant’s guilt.
• The State supported the High Court’s judgment and requested the Supreme Court to uphold the conviction.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues but considered the primary question of whether the conviction of the appellant based on circumstantial evidence was justified.

Treatment of the Issue by the Court

Authorities

The Supreme Court did not explicitly cite any specific cases or books in this judgment. The court primarily relied on the factual evidence presented by the prosecution witnesses and the circumstances surrounding the incident.

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following:

• The fact that the appellant and the deceased were alone in the office at the time of the incident.
• The appellant’s failure to provide any reasonable explanation for the deceased’s death.
• The corroborative evidence of multiple witnesses, which supported the prosecution’s case.
• The appellant’s attempt to divert the police by making a false call to the control room.

The court noted, “Under the above circumstance, it was for the accused to explain under what circumstances the deceased was dead.” The court further stated, “We are of the view that the chain of circumstances has been completely proved and established beyond reasonable doubt.” Additionally, the court observed, “Therefore, we find no reason to interfere with the concurrent findings of the courts below.”

The Supreme Court upheld the concurrent findings of the lower courts, emphasizing that the chain of circumstances was completely proved and established beyond a reasonable doubt. The Court found no reason to interfere with the conviction.

Key Takeaways

• In cases of custodial death, the burden of proof shifts to the accused to provide a reasonable explanation if the circumstances point towards their involvement.
• The court will consider circumstantial evidence in a holistic manner, not in isolation, to determine guilt.
• False attempts to divert the police can be used as evidence against the accused.
• Concurrent findings of lower courts are generally upheld by the Supreme Court unless there is a clear error in law or fact.

Directions

The Supreme Court did not issue any specific directions in this case.

Development of Law

The ratio decidendi of this case is that in cases of custodial death, where the accused and the deceased were alone at the time of the incident, and the accused fails to provide a reasonable explanation, the court can convict based on circumstantial evidence if a complete chain of circumstances is established. This case reinforces the principle that circumstantial evidence can be sufficient to establish guilt beyond a reasonable doubt, especially when the accused fails to offer a cogent explanation.

Conclusion

The Supreme Court dismissed the appeal and upheld the conviction of the appellant, affirming the judgments of the lower courts. The court concluded that the prosecution had successfully established a complete chain of circumstances proving the appellant’s guilt in the custodial death of the police constable.