Supreme Court Acquits Man in 2014 Tamil Nadu Murder Case Due to Lack of Proper Identification

The case of P. Sasikumar vs. State Rep. by the Inspector of Police is a significant ruling concerning criminal identification and fair trial principles. The Supreme Court overturned the conviction of the appellant for the brutal murder of a 14-year-old girl, citing a lack of proper identification and procedural lapses in the investigation. The Court emphasized that in cases relying on circumstantial evidence, adherence to due process is crucial.

Background of the Case

The case pertains to the murder of a 14-year-old girl in her house on November 13, 2014, in Salem, Tamil Nadu. According to the prosecution, two individuals, including the appellant, entered her home, attacked her, and fled. The father of the deceased, who arrived home shortly after the incident, found his daughter critically injured. She was taken to the hospital but succumbed to her injuries.

The police investigation relied on circumstantial evidence, eyewitness testimonies, and forensic findings to establish the guilt of the accused. The appellant was convicted under Sections 302 (murder), 34 (common intention), 449 (house trespass to commit a crime), 404 (dishonest misappropriation of property), and 201 (causing disappearance of evidence) of the Indian Penal Code (IPC). The trial court sentenced him to life imprisonment, and the High Court upheld the conviction. The appellant then approached the Supreme Court.

Petitioner’s Arguments

The appellant’s counsel presented the following key arguments:

The case was based on circumstantial evidence, and there was no direct proof linking the appellant to the crime.
The main eyewitness, PW-5, identified the appellant for the first time in court, despite never having seen him before.
No Test Identification Parade (TIP) was conducted, violating due process.
The prosecution’s case relied on a “green monkey cap” worn by the appellant, making visual identification unreliable.
The investigating officer failed to obtain proper authorization for recoveries made during the investigation.
The absence of a clear motive for the appellant further weakened the prosecution’s case.

Respondent’s Arguments

The prosecution countered with the following points:

The appellant was seen leaving the crime scene by eyewitnesses, including the deceased’s father (PW-1).
Blood-stained clothes and other incriminating materials were recovered from the appellant.
The appellant was arrested shortly after the crime, and circumstantial evidence strongly pointed to his involvement.
The High Court rightly upheld the conviction based on available evidence.

Supreme Court’s Observations

The Supreme Court examined the evidentiary gaps and inconsistencies in the prosecution’s case. The judgment highlighted key principles concerning criminal identification:

“The identification of an accused must be free from doubt. When a Test Identification Parade (TIP) is not conducted, dock identification alone cannot be the basis for conviction, especially when the witness has never seen the accused before.”

The Court criticized the prosecution’s reliance on eyewitnesses who had only seen the appellant wearing a monkey cap, stating:

“A monkey cap covers most of the face, making reliable identification difficult. In such cases, an identification parade is necessary to ensure fair trial standards.”

The Court also pointed out that the investigating officer failed to conduct a TIP and did not provide any justification for this lapse. This failure, combined with the weak evidentiary value of dock identification, made the prosecution’s case untenable.

Final Verdict

The Supreme Court ruled in favor of the appellant, stating:

“The prosecution has failed to establish the identity of the appellant beyond reasonable doubt. The appeal is allowed, and the conviction is set aside.”

The Court ordered the immediate release of the appellant unless he was required in any other case.

Implications of the Judgment

This ruling underscores the importance of procedural fairness and reliable identification in criminal trials. Key takeaways include:

Test Identification Parades (TIP) are crucial: In cases where the accused is a stranger to witnesses, conducting a TIP is essential for fair identification.
Dock identification is weak evidence: Identifying an accused for the first time in court without prior corroboration through a TIP is unreliable.
Failure to follow due process weakens prosecution cases: Investigators must ensure that evidence is collected lawfully and systematically.
Convictions based on circumstantial evidence require high scrutiny: Courts must carefully evaluate the chain of evidence to prevent wrongful convictions.

Conclusion

The Supreme Court’s decision in this case reinforces the principle that criminal convictions must be based on credible and legally admissible evidence. By overturning the conviction due to unreliable identification and investigative lapses, the judgment upholds the fundamental right to a fair trial and sets a precedent for future cases involving circumstantial evidence.

Petitioner Name: P. Sasikumar.
Respondent Name: State Rep. by the Inspector of Police.
Judgment By: Justice Sudhanshu Dhulia, Justice Prasanna B. Varale.
Place Of Incident: Salem, Tamil Nadu.
Judgment Date: 08-07-2024.

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