Supreme Court Upholds Conviction in Murder Case Based on Circumstantial Evidence: Sadayappan vs. State (26 April 2019)

Introduction

Date of the Judgment: 26 April 2019

Citation: (2019) INSC 389

Judges: N.V. Ramana, J., Mohan M. Shantanagoudar, J.

Can a conviction for murder be upheld solely based on circumstantial evidence and the testimonies of witnesses related to the deceased? The Supreme Court of India recently addressed this question in the case of Sadayappan @ Ganesan vs. State. This case explores the validity of a murder conviction where there were no direct eyewitnesses, relying instead on a chain of circumstantial evidence and the testimonies of family members of the victim. The judgment, delivered by a two-judge bench comprising Justices N.V. Ramana and Mohan M. Shantanagoudar, upheld the conviction, emphasizing the reliability of the circumstantial evidence and the credibility of the related witnesses.

Case Background

The case revolves around the murder of Selvam @ Thangaraj, who had a land dispute with Karuppusamy (A1) and Sadayappan @ Ganesan (A2), the appellant. About 15 years prior to the incident, Thangaraj had paid Rs. 30,000 to A1 for a piece of land but the sale deed was never registered. Sadayappan (A2), a neighboring landowner, consistently supported A1 in delaying the land registration. Despite this animosity, all three men continued to go hunting together. On May 27, 2008, at around 11 p.m., A1 and A2 went to Thangaraj’s house and insisted that he join them in the fields/forest. When Thangaraj did not return by 4 a.m., his wife, Rajammal (PW1), sent his brother Palanisamy (PW2) and nephew Govindarajan (PW3) to search for him. They found his dead body with bleeding injuries near the fields.

Timeline

Course of Proceedings

The Trial Court convicted Sadayappan (A2) under Section 302 read with Section 34 of the Indian Penal Code (IPC), sentencing him to life imprisonment and a fine of Rs. 10,000. The High Court of Judicature at Madras dismissed the appeal, upholding the Trial Court’s decision. Both accused filed separate appeals before the Supreme Court. However, the appeal of A1 abated due to his death. The Supreme Court then heard the appeal of A2.

Legal Framework

The case primarily involves Section 302 of the Indian Penal Code (IPC), which defines the punishment for murder, and Section 34 of the IPC, which deals with acts done by several persons in furtherance of common intention.

• Section 302, Indian Penal Code (IPC): This section prescribes 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 34, Indian Penal Code (IPC): This section defines the concept of common intention. It states: “When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.”

Arguments

The appellant’s counsel argued that the lower courts incorrectly relied on the testimonies of interested witnesses, who were relatives of the deceased. They contended that the chain of circumstantial evidence was incomplete and that the appellant did not have a motive to commit the crime. The counsel also stated that the land dispute between A1 and the victim had been settled amicably in the panchayat, and that the three men were on friendly terms, as evidenced by their hunting trips.

The State’s counsel supported the High Court’s judgment, arguing that there was no reason for the Supreme Court to interfere with it.

The innovativeness of the argument by the appellant was to highlight that the prior enmity was not a valid motive as the same had been settled in the panchayat.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues but addressed the core question of whether the conviction based on circumstantial evidence and related witnesses’ testimonies was valid.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authority:

Judgment

The Court considered the following authorities:

• Sudhakar v. State, (2018) 5 SCC 435: The Supreme Court relied on this case to clarify the distinction between “related” and “interested” witnesses. The court stated that a witness cannot be considered “interested” solely because they are related to the victim.

What weighed in the mind of the Court?

The Court’s decision was primarily influenced by the reliability of the circumstantial evidence and the credibility of the witnesses. The Court emphasized that the witnesses, though related to the deceased, did not have any vested interest in falsely implicating the accused. The fact that the accused were the last people seen with the deceased, combined with the forensic evidence, strongly supported the prosecution’s case. The Court also noted that the prior land dispute served as a motive for the crime.

The court’s reasoning was based on a thorough analysis of the facts and the law.

The Court considered the argument that the witnesses were related to the deceased but rejected this argument by stating that the witnesses were not “interested” as they did not have any vested interest in falsely implicating the accused. The Court also considered the argument that the chain of circumstantial evidence was incomplete, but rejected this argument by stating that the circumstantial evidence, including the last seen evidence, the prompt complaint, and the forensic evidence, was sufficient to prove the prosecution’s case beyond reasonable doubt.

The court quoted from the judgment:

“Criminal law jurisprudence makes a clear distinction between a related and interested witness. A witness cannot be said to be an “interested” witness merely by virtue of being a relative of the victim.”

“The witness may be called “interested” only when he or she derives some benefit from the result of a litigation in the decree in a civil case, or in seeing an accused person punished.”

“After thoroughly scrutinizing their evidence, we do not find any direct or indirect interest of these witnesses to get the accused punished by falsely implicating him so as to meet out any vested interest.”

Key Takeaways

• A conviction for murder can be based on circumstantial evidence if the chain of circumstances is complete and the evidence is reliable.
• The testimony of related witnesses is admissible and credible unless there is a clear indication of a vested interest in falsely implicating the accused.
• Prior disputes can establish motive for a crime.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that a conviction for murder can be based on circumstantial evidence and the testimonies of related witnesses if the evidence is reliable and the witnesses do not have a vested interest in falsely implicating the accused. This case reinforces the principle that circumstantial evidence can be sufficient for a conviction and clarifies the distinction between “related” and “interested” witnesses. There is no change in the previous position of law.

Conclusion

The Supreme Court upheld the conviction of Sadayappan @ Ganesan for murder, affirming that circumstantial evidence and the testimonies of related witnesses can be sufficient for conviction if the evidence is reliable and the witnesses do not have a vested interest in falsely implicating the accused. The Court’s decision underscores the importance of a thorough analysis of all evidence and the credibility of witnesses in criminal cases.