Myladimmal Surendran v State of Kerala with Arayakkamdy Sukumaran v State of Kerala
In Myladimmal Surendran v State of Kerala (with Arayakkamdy Sukumaran v State of Kerala), Justice Surinder Singh Nijjar affirmed the judgment of the Kerala High Court, which had upheld the conviction of the appellants under Sections 143, 147, 148, 341, and 302 read with Section 149 IPC while commuting their death sentences to life imprisonment.
In dismissing the appeals, the Supreme Court addressed the evidentiary weight of street bystanders, firmly rejecting the practice of casually discarding material witnesses as “chance witnesses.”
Citing Sachchey Lal Tiwari v State of UP, the Court explained that crimes are not committed with advance notice to observers; thus, occupants are natural witnesses inside a home, just as passersby are natural witnesses on a street.
The Court emphasized that the Western notion of a “chance witness”—which expects a formal explanation for a person’s presence outside their home—is ill-suited to the more casual social fabric of India.
Reaffirming the statutory definitions under Section 300 IPC, the Court held that the testimony of present bystanders cannot be viewed with automatic suspicion, ultimately finding no reason to interfere with the convictions.
Vinod Kumar v Amritpal @ Chhotu & Ors.
In Vinod Kumar v Amritpal @ Chhotu & Ors., Justices Ajay Rastogi and Abhay S. Oka set aside a Rajasthan High Court decision that had improperly downgraded the conviction of five respondents from murder under Section 302/149 IPC to culpable homicide under Section 304 Part II IPC.
The Sessions Court had originally sentenced the accused to life imprisonment for murder, rioting, and kidnapping, ordering compensation to the victim’s widow after an attack that fractured the deceased’s 6th to 10th ribs, ruptured his right lung and liver, and ended with the accused smashing his face before throwing his body into a canal.
The Supreme Court held that the High Court proceeded on an erroneous factual footing by claiming no vital organs were harmed, despite medical board evidence confirming that internal bleeding and shock from the lung and liver injuries directly caused death.
Reaffirming the foundational principle from Virsa Singh v State of Punjab, the Apex Court emphasized that Clause “Thirdly” of Section 300 IPC applies whenever an intended physical injury is objectively sufficient to cause death in the ordinary course of nature, without requiring additional proof of subjective fatal intent or knowledge.
Consequently, the Supreme Court restored the trial court’s life imprisonment sentence under Section 302/149 IPC and ordered the respondents to surrender within six weeks, aligning with established jurisprudence (such as the 2017 honour-killing precedent) where severe, deliberate trauma to vital body parts warrants the full penalty for murder.
Gandi Doddabasappa alias Gandhi Basavaraj v State of Karnataka
In Gandi Doddabasappa alias Gandhi Basavaraj v State of Karnataka, Justice A.M. Khanwilkar addressed an appeal where the father killed his daughter, Shilpa, in an honor killing after she entered into an inter-caste marriage.
Following explicit threats to “finish” her for marrying into a lower caste, the appellant attacked Shilpa—who was in an advanced stage of pregnancy—in a public toilet, where her mother-in-law saw him exiting with a blood-stained sickle before he threw the weapon into a manure pit and fled.
While the Sessions Court originally acquitted the accused, the High Court of Karnataka reversed the acquittal to convict him under Section 304 Part I IPC with a 10-year sentence.
On further appeal, the Supreme Court held that because none of the five exceptions to Section 300 IPC applied to such a premeditated act, the High Court erred in its reduced charge; the Court subsequently enhanced the conviction to murder under Section 302 IPC and sentenced the appellant to life imprisonment.
State of UP v Krishna Master
In State of UP v Krishna Master, Justice A.K. Pattnaik delivered a judgment allowing the State’s appeal against an Allahabad High Court ruling that had acquitted 18 accused involved in the brutal massacre of seven members of a Harijan family in Fatehpur district.
In September 1979, an armed upper-caste mob tied seven victims with ropes, shot them, and threw them into strong currents of the Ganges River, leaving five bodies unrecovered.
The trial court had sentenced the perpetrators to life imprisonment under Section 302 read with Section 149 IPC alongside Section 201 IPC.
Reversing the High Court’s blanket acquittal and restoring convictions for six key accused, the Supreme Court ruled that the High Court took a patently illegal approach by dismissing eyewitness Kallu’s survival efforts, clarifying that hiding from violent attackers is an instinctual act of self-preservation.
The Court reaffirmed its wide appellate powers under Sections 378 and 386 CrPC to correct High Court decisions that produce a grave miscarriage of justice.
Concluding the judgment, the Court condemned the persistent plague of caste-based violence and honor killings—referencing horrific incidents like the 2010 Ashok Vihar triple murders and noting 19 honor killings within an 80-day span—and called for the urgent abolition of the caste system to safeguard the rule of law.
Sidhartha Vashisht @ Manu Sharma v State (NCT of Delhi)
In Sidhartha Vashisht @ Manu Sharma v State (NCT of Delhi), the Supreme Court upheld the conviction and life sentence of Manu Sharma for the 1999 murder of Jessica Lal, affirming the Delhi High Court’s reversal of an earlier trial court acquittal.
Justices P. Sathasivam and Swatanter Kumar found that overwhelming evidence—including eyewitness testimonies, emergency call records, ballistic connections to a .22 Beretta pistol, and the accused’s post-crime conduct of absconding and delivering false statements—proved guilt beyond reasonable doubt.
Beyond the core evidentiary findings, the judgment addressed broader systemic issues, drawing a line between legitimate reporting and “trial by media” that threatens constitutional guarantees under Articles 19(1)(a) and 21.
The Court also stressed the importance of preserving judicial dignity across court tiers and called for dedicated witness protection legislation to shield individuals from intimidation by influential figures.
Amit v State of UP
In Amit v State of UP, Justices A.K. Pattnaik and Swatanter Kumar adjudicated an appeal concerning the kidnapping, sexual assault, and murder of a 3-year-old girl named Monika, who was abducted under the guise of being offered biscuits.
Following an investigation, the trial court convicted the accused under Sections 364, 376, 377, 302, and 201 of the IPC, awarding a death sentence under the “rarest of rare” doctrine, which was subsequently confirmed by the High Court.
Upon review, the Supreme Court upheld the conviction based on established circumstantial evidence but commuted the death sentence to life imprisonment extending to full life, while leaving open the possibility of executive remission for sufficient reasons.
G Parshwanath v State of Karnataka
In G Parshwanath v State of Karnataka, Justice J.M. Panchal delivered a judgment dismissing the appeal of a husband convicted under Sections 302 and 201 IPC for the murder of his wife, Chethana, and their young son in Bellary.
The prosecution established a complete chain of circumstantial evidence: the deceased had phoned her parents regarding ongoing domestic abuse hours before the incident, traces of kerosene were found on the charred bodies, and the house door had been locked from the outside, ruling out both suicide and third-party involvement.
Additionally, the prosecution proved motive through evidence of the husband’s suspicion regarding the child’s paternity, his failed divorce proceedings, and his desire to marry another woman.
Concluding that the trial court and High Court properly evaluated the evidence without error, the Supreme Court affirmed the sentence of life imprisonment, emphasizing that the unbroken circumstantial facts and the appellant’s conduct excluded every reasonable hypothesis of innocence.
Satpal v State of Haryana
In Satpal v State of Haryana, Justice Navin Sinha delivered the Supreme Court’s decision dismissing the appellant’s appeal against his conviction under Sections 302 and 201 of the IPC, which had been previously affirmed by the High Court and Additional Sessions Judge, Hissar.
The prosecution established that the accused was last seen with the 13-year-old victim, Kapil Kumar, and failed to produce any evidence showing that they had separated prior to the crime.
Reaffirming key principles on circumstantial evidence, the Apex Court ruled that an FIR need not act as an exhaustive encyclopedia, meaning minor omissions like prior altercations do not undermine prosecution credibility.
Furthermore, the Court relied on the credible testimonies of relative witnesses, physical recoveries made under confession—including an Atlas bicycle and an inscribed milk-can—and the appellant’s abscondence until his 2007 arrest to hold that the unbroken chain of circumstantial evidence established guilt beyond reasonable doubt.
Ganpat Singh v State of MP
In Ganpat Singh v State of MP, Justice Dr. D.Y. Chandrachud delivered the Supreme Court’s judgment setting aside the life sentence and conviction under Section 302 IPC that had been awarded by the Additional Sessions Judge and affirmed by the Madhya Pradesh High Court.
The prosecution’s case against the appellant rested on circumstantial evidence, primarily that he was last seen in the company of the deceased (Shantabai), made a false statement to her minor son regarding her whereabouts, and led to the recovery of her body.
Reinterpreting these findings, the Apex Court reiterated that a conviction based on circumstantial evidence demands an unbroken chain of proved facts consistent solely with the guilt of the accused.
The Court held that the “last seen” theory was unsafe to rely upon due to a significant time gap, as medical evidence placed the time of death between two to four weeks prior to the recovery of the body.
Consequently, the Supreme Court ruled that the prosecution failed to exclude every alternative hypothesis of innocence, allowing the appeal and setting aside the conviction by granting the appellant the benefit of doubt.
Dilip Mallick v State of WB
In Dilip Mallick v State of WB, Justice L. Nageswara Rao delivered the Supreme Court’s judgment affirming the decision of the High Court of Calcutta and the Additional Sessions Judge, Siliguri, which had convicted the appellant under Section 302 of the IPC and sentenced him to life imprisonment.
The case arose following the discovery of the decapitated body of the victim at the Chandmuni Tea Estate on 3 February 2004.
The prosecution’s case relied heavily on consistent testimonies from the victim’s family members (PW-3, PW-4, and PW-5), who established that the accused was last seen with the deceased at approximately 2:00 PM the previous day.
In dismissing the appeal, the Apex Court emphasized that the appellant failed to meet the legal burden of explaining what occurred after they left together and actively attempted to mislead others about the victim’s whereabouts.
Concluding that the lack of material recovery did not weaken the otherwise complete and unbroken chain of circumstantial evidence, the Court upheld the conviction and ordered the appellant to surrender immediately to serve his sentence.
Satish Nirankari v State of Rajasthan
In Satish Nirankari v State of Rajasthan, Justice A.K. Sikri set aside the appellant’s murder conviction under Section 302 IPC, holding that the prosecution failed to prove guilt beyond reasonable doubt.
The case involved a missing young woman, Pooja, who had left for classes to meet the appellant—with whom she was in a relationship—resulting in an incident where both ingested poison, leading to her death and the appellant’s 50-day hospitalization.
Rebutting the High Court’s reliance on speculation regarding the victim’s career ambitions and unproven allegations of forced poison and strangulation, the Supreme Court pointed out that the appellant’s conduct—raising alarms, attempting to save her, notifying her family, and taking poison himself—was entirely inconsistent with a murder intent.
Furthermore, medical findings evaluated under Modi’s Medical Jurisprudence confirmed an intact hyoid bone, dribbling saliva, and an oblique upward ligature mark without homicidal trauma, leading the Apex Court to rule that the death was not homicidal and allowing the appeal due to missing links in the circumstantial chain.
Sattatiya @ Satish Rajanna Kartalla v State of Maharashtra
In Sattatiya @ Satish Rajanna Kartalla v State of Maharashtra, Justice G.S. Singhvi delivered the Supreme Court’s judgment setting aside the life sentence and conviction under Section 302 IPC.
The trial court and Bombay High Court had convicted the appellant primarily on circumstantial grounds: the “last seen” theory, along with the recovery of a blood-stained shirt, pants, half blade, and a handkerchief linked to the crime scene.
Re-evaluating the evidence, the Supreme Court highlighted critical investigative and evidentiary defects.
The prosecution failed to produce written records of the appellant’s disclosure statement initiating the recoveries, rendering the recovery evidence highly suspect.
Furthermore, while chemical reports detected human blood on the seized items, the prosecution failed to match the blood group to the deceased.
Consequently, the Apex Court ruled that the prosecution failed to establish an unbroken chain of circumstantial evidence, allowing the appeal and setting aside the conviction.
Podyami Sukada v State of MP (New Chhattisgarh)
In Podyami Sukada v State of MP (New Chhattisgarh), Justice C.K. Prasad delivered the Supreme Court judgment setting aside the appellant’s life imprisonment and conviction under Section 302 of the IPC.
The prosecution had alleged that on 8 December 1999, the appellant fatally assaulted his mother, Madvi Mase, with a burning teak wood plank following a domestic dispute.
While both the trial court and the High Court affirmed the conviction based on an extra-judicial confession made before village elders and corroborated by weapon recovery, the Supreme Court evaluated the evidence as “slippery” and unreliable, ruling that it failed to prove beyond reasonable doubt that a confession was ever made.
Establishing that weapon recovery alone is insufficient to sustain a murder conviction when primary confession evidence lacks credibility, the Apex Court granted the appellant the benefit of doubt and allowed the appeal.
Gulzari Lal v State of Haryana
In Gulzari Lal v State of Haryana, Justice V. Gopala Gowda delivered the Supreme Court judgment affirming the decisions of the High Court of Punjab & Haryana and the Fast Track Court, Hisar, which had convicted the appellant under Sections 302 and 323 read with Section 34 of the IPC.
Addressing the appellant’s primary challenge regarding the non-recovery of blood-stained earth from the scene of the crime, the Apex Court ruled that police investigative laxity cannot eclipse strong, direct evidence.
Finding the dying declaration recorded by Head Constable Manphool Singh trustworthy and fully supported by reliable eyewitness testimony and forensic evidence linking the deceased’s blood to the recovered weapons and clothing, the Supreme Court held that the absence of a proven motive was inconsequential and dismissed the appeal.
Kara Bhai v State of Gujarat
In Kara Bhai v State of Gujarat (Supreme Court, 2016), the Apex Court dismissed the appeal and restored the conviction of the appellant under Section 302 read with Section 34 of the Indian Penal Code, 1860.
The facts established that Accused 1 (Bhima) and Accused 2 (Kara Bhai) jointly went to the victim’s house, called him out, and immediately launched a fatal knife attack on him.
Addressing the question of individual liability, the Supreme Court held that where multiple individuals act in furtherance of a common intention, the prosecution is not required to single out which specific accused delivered the fatal strike, as joint liability under Section 34 IPC is fully attracted.
Furthermore, the Court validated the properly recorded dying declaration (Ex PF/1), noting that it was reliably corroborated by witness Pyarelal (PW-3), who identified the accused, proved the sequence of events, and established the underlying motive.
Shama v State of Haryana
In Shama v State of Haryana, Justice Abhay Manohar Sapre delivered the judgment of the Supreme Court, dismissing the appeal and affirming the decision of the High Court of Punjab and Haryana, which had upheld the life sentences handed down by the Additional Sessions Judge, Hisar, under Section 302 read with Section 34 of the Indian Penal Code.
The prosecution established that on 9 October 1997, the victim, Naurang, was intercepted on his way to work by Sube Singh, his brother Shama, and Jai Singh on a scooter, following family animosity stemming from an inter-family marriage.
Jai Singh identified Naurang before firing a fatal pistol shot into his abdomen.
Following his admission to General Hospital, Hansi, Inspector Mam Chand obtained formal medical certification of Naurang’s mental fitness from Dr. S.K. Gupta (PW-1) before recording his statement (Ex. PF/1).
Naurang subsequently passed away, and his statement was admitted as a valid dying declaration.
The Supreme Court concluded that the certified dying declaration, alongside proof of common intention, fully substantiated the conviction of the co-accused, thereby upholding the trial court’s sentence.
State of Gujarat v Jayrajbhai Punjabhai Varu
In State of Gujarat v Jayrajbhai Punjabhai Varu, Justice R.K. Agrawal delivered the Supreme Court’s judgment dismissing the State’s appeal and upholding the High Court’s acquittal of the respondent husband.
The case centered on the death of Rekhaben, who died from 90% burn injuries.
Before her death, she made consistent, official written dying declarations to both police officers and an Executive Magistrate stating that an unknown outsider wearing white clothes had poured kerosene on her and set her on fire.
Despite the trial court’s initial conviction based on an uncorroborated oral statement reported by her father, the Supreme Court emphasized that official, written dying declarations recorded under due procedure take precedence over unverified oral claims.
Reaffirming that dying declarations require careful judicial scrutiny due to the absence of cross-examination and that any reasonable doubt or dual interpretation of evidence must benefit the accused, the Apex Court ruled that there was no evidence linking the husband to the crime.
Amarsingh Munnasingh Suyawanshi v State of Maharashtra
In Amarsingh Munnasingh Suyawanshi v State of Maharashtra, Justice S.B. Sinha delivered the Supreme Court judgment dismissing the appeal and upholding the appellant’s life conviction under Section 302 of the IPC, 1860.
The facts established that on 7 June 1990, the unemployed and liquor-addicted appellant poured kerosene from a lamp onto his wife, Kamlabai, and set her ablaze while she was serving him dinner.
Before succumbing to her injuries, Kamlabai gave two consistent dying declarations—one to a police constable and another to a Special Judicial Magistrate—directly implicating her husband.
The Supreme Court emphasized that because the husband and wife were alone in their room during the incident, the failure of the accused to offer any explanation for her homicidal death, combined with his unexplained absconding for nearly a month, pointed directly to his guilt.
Reaffirming the principle that a genuine and voluntary dying declaration is sufficient on its own to sustain a murder conviction, the Apex Court affirmed the findings of the lower courts.
Kuchibotla Saran Kumar v State of AP
In Kuchibotla Saran Kumar v State of AP, Justice Harjit Singh Bedi delivered the judgment of the Supreme Court dismissing the appeal and affirming the life imprisonment sentence awarded under Section 302 of the Indian Penal Code, 1860.
The facts established that after the breakdown of their engagement—which was scheduled for 23 March 2000—the accused threatened to kill the deceased, P. Sesha Sudha, a college lecturer in Vishakhapatnam.
On 8 February 2000, the accused lured her to an empty Electrical Engineering Laboratory during a college sports day, strangulated her using her own chunni (dupatta), and concealed her body in a corner before fleeing.
The body was discovered the following morning when the lab reopened.
Concluding that the circumstantial evidence, motive, and deliberate execution of the crime were fully proved beyond reasonable doubt, the Supreme Court held the appeal to be devoid of merit and confirmed the conviction.
Aftab Ahmad Anasari v State of Uttaranchal
In Aftab Ahmad Anasari v State of Uttaranchal, the Supreme Court dismissed the appeal and upheld the conviction of the appellant under Sections 302, 376, and 201 of the Indian Penal Code.
The case involved the sexual assault and murder of a five-year-old child, whose body was discovered on a public pathway days after her disappearance.
The prosecution’s case rested on a complete chain of circumstantial evidence: the appellant was spotted fleeing the scene shortly before the body’s discovery, his disclosure statement led to the recovery of the victim’s concealed blood-stained clothing, forensic tests confirmed blood and semen on his own seized clothing, and he made a credible extra-judicial confession to the village’s ex-pradhan.
Reaffirming the modified sentence of life imprisonment substituted by the High Court, the Supreme Court ruled that the cumulative effect of these facts established the appellant’s guilt beyond reasonable doubt, demonstrating within all human probability that he committed the rape, murder, and destruction of evidence.