Death Sentence Upheld in Heinous Child Rape and Murder Case: Supreme Court’s Landmark Judgment
The Supreme Court of India recently delivered a significant judgment in the case of Manoharan vs. State by Inspector of Police, Variety Hall Police Station, Coimbatore, involving the brutal rape and murder of two children. The case, arising from a shocking crime committed in 2010, tested the judiciary’s stance on the death penalty for the most heinous offenses.
Background of the Case
On October 29, 2010, a man named Mohanakrishnan abducted two children—a 10-year-old girl and her 7-year-old brother—while they were on their way to school in Coimbatore. He was later joined by the appellant, Manoharan, and together they took the children to a secluded area. The prosecution established that the girl was brutally raped, and both children were subsequently poisoned and thrown into the Parambikulam-Aliyar Project (PAP) canal, where they drowned.
The crime came to light when school bags belonging to the children were discovered floating in the canal. The police arrested Mohanakrishnan and Manoharan shortly after the bodies were recovered. However, Mohanakrishnan was killed in a police encounter, leaving Manoharan as the sole accused in the case.
Legal Issues in the Case
The case raised several key legal questions:
- Whether the evidence conclusively proved Manoharan’s involvement in the crime.
- Whether his confessional statement was voluntary and could be relied upon.
- Whether the circumstances of the case warranted the death penalty.
Trial Court and High Court Verdicts
The trial court convicted Manoharan under multiple sections of the Indian Penal Code (IPC), including:
- Section 302 (Murder)
- Section 376(2)(f) (Rape of a minor)
- Section 376(2)(g) (Gang rape)
- Section 201 (Causing disappearance of evidence)
He was sentenced to death for the murders, life imprisonment for the rape, and additional imprisonment for the other charges.
The Madras High Court upheld the trial court’s decision, finding no mitigating circumstances to justify a lesser sentence.
Supreme Court’s Observations
The Supreme Court examined several crucial aspects of the case:
1. Last Seen Theory
Multiple witnesses placed Manoharan and Mohanakrishnan with the children on the day of the crime. The Court noted:
“After closely scrutinizing the evidence of several witnesses, we have no hesitation in concluding that the prosecution has proved beyond reasonable doubt that Manoharan and Mohanakrishnan were last seen with the children.”
2. Confessional Statement
Manoharan voluntarily confessed before a magistrate, providing graphic details of the crime. The Court rejected his later retraction, observing:
“The Magistrate ensured that the confession was voluntary by questioning the accused over two days. The confession aligns with forensic evidence and witness testimonies.”
3. DNA Evidence
The forensic report confirmed the presence of Manoharan’s pubic hair on the victim’s underwear. The Court stated:
“This irrefutable forensic evidence corroborates the prosecution’s case and eliminates any doubt regarding the appellant’s involvement.”
4. Nature of the Crime
The Court noted the extreme brutality of the offense:
“The victim was first raped vaginally and anally, then poisoned, and finally thrown into the canal while still alive. The crime was committed in a cold, calculated manner.”
Arguments by the Defense
The defense raised several arguments:
- Manoharan was merely a passive participant and did not rape the victim.
- His confession was coerced.
- The death penalty was excessive given his young age and lack of prior convictions.
Arguments by the Prosecution
The prosecution countered:
- Manoharan actively participated in both the rape and murder.
- His confession was voluntary and corroborated by forensic evidence.
- The crime was among the most heinous and warranted the harshest punishment.
Supreme Court’s Final Judgment
The Supreme Court upheld Manoharan’s conviction and confirmed the death sentence, stating:
“This crime falls within the ‘rarest of rare’ category. The manner in which the children were assaulted and killed justifies the imposition of the death penalty.”
However, one of the three judges dissented on the question of the death penalty. Justice Sanjiv Khanna, while agreeing with the conviction, opined that life imprisonment without remission would be more appropriate:
“The possibility of reform and rehabilitation must be considered. The appellant should serve life imprisonment without the possibility of remission.”
Conclusion
This judgment reinforces the Supreme Court’s stance that the death penalty should be reserved for the most extreme cases where rehabilitation is not an option. The case serves as a landmark ruling on the application of capital punishment for heinous crimes against children.
Petitioner Name: Manoharan.Respondent Name: State by Inspector of Police, Variety Hall Police Station, Coimbatore.Judgment By: Justice R.F. Nariman, Justice Surya Kant, Justice Sanjiv Khanna.Place Of Incident: Coimbatore, Tamil Nadu.Judgment Date: 01-08-2019.
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