Case Name: Agniraj & Ors. v. State through Deputy Superintendent
of Police CB-CID
Case Number: Criminal Appeal Nos. 1686–1688 of 2023
Date of Judgment: 23 May 2025
Quorum: Justices Abhay S. Oka and Ujjal Bhuyan
FACTUAL BACKGROUND
These criminal appeals followed an order dated 21 March 2019 of the Madras High Court (Madurai Bench), affirming the conviction of Accused Nos. 1 to 11 for offences under Sections 302 and 307 read with Section 149 IPC, Section 3(1) of the Tamil Nadu Prevention of Damage to Public Property Act, and other such provisions. The prosecution stated that the night of 14 November 2012 incident was the culmination of a political rivalry between the deceased’s family and the accused that had been going on for a long time. It was a vicious assault on a vehicle transporting Kathiresan (Deceased No. 1), his son Prasanna (Deceased No. 2), daughter Nikila (PW-9), and their driver (Deceased No. 3). The prosecution’s case was predominantly based upon the evidence of eyewitnesses and forensic experts. The Trial Court convicted 11 out of 21 accused persons, sentencing them to life imprisonment. The High Court confirmed this conviction. The instant appeal assailed the concurrent findings.
ISSUES FOR DETERMINATION
- Whether the prosecution established the guilt of the accused beyond reasonable doubt?
- Whether the contemporaneous observations of the Trial Court and the High Court were perverse, justifying interference under Article 136 of the Constitution?
LEGAL PROVISIONS
Sections 147, 148, 149, 302 and 307 of IPC. Section 3(1) of Tamil Nadu Prevention of Damage to Public Property Act. Article 136 of Constitution of India
APPELLANTS’ CONTENTIONS
The appellants contended that the convictions rested on untrustworthy and conflicting testimonies. They raised doubts regarding the believability of PW-1 (Krishnan), the key eyewitness, on the basis of exaggeration and belated reporting. They argued that the FIR was registered two hours after the incident, not at the same time as the purported narration to the police at the site of the crime. They questioned the credibility of PW-2, who reported only 43 days after the occurrence. As far as PW-9, a minor witness, was concerned, they contended that the court had not made the preliminary inquiry necessary to gauge her capacity, thus rendering her evidence vitiated. The recovery and fingerprint evidence, they submitted, was not backed by adequate procedural safeguards in the form of mahazars and photo exhibits.
RESPONDENT’S CONTENTIONS
The State contended that the evidence of PW-1, PW-2, and PW-9 was consistent and corroborated by medical and forensic evidence. It explained the postponement of FIR registration and recording of statements because the crime was serious in nature. It also argued that in instances of such violence, human conduct is different and cannot be judged strictly. It argued that the courts below had properly evaluated the credibility of the witnesses and asked the Supreme Court to uphold the concurrent findings under the self-restraints of Article 136.
ANALYSIS
The Supreme Court carried out a very careful examination of the evidence, recognizing its restricted jurisdiction under Article 136 but claiming that it can intervene in cases of clear illegality. The Court held the evidence of PW-1 (Krishnan) to be full of contradictions, politically motivated, and confessed exaggerations. PW-2’s undue delay in approaching the court without adequate reason made his evidence unreliable. PW-9’s testimony was dismissed because the Trial Court did not administer a voir dire test to evaluate her as a minor witness. The forensic evidence also suffered from procedural sanctity deficiency—no mahazars were prepared while fingerprint photographs were said to be taken, and the recovery of weapons was found to be staged and suspicious because of repeated recovery from the same spot at alternate intervals. Paint flake evidence was procedurally flawed as well. The Court held that, aside from the testimonies of the three main witnesses and the faulty corroborative evidence, the case depended entirely on recoveries, and they were not enough to uphold convictions in a murder case.
JUDGMENT
The appeals were granted. The appellants’ convictions were quashed. The Supreme Court acquitted the accused on the ground that their guilt was not established beyond reasonable doubt. The Court directed the release of the appellants forthwith unless necessary in any other case.
CONCLUSION
The decision is a strong support of the precept that convictions must be based on impeccable and legal evidence. It emphasizes the dangers of politically motivated prosecutions and reaffirms the willingness of the Supreme Court to intervene where there is evident miscarriage of justice, even in the face of concurrent findings. It also reasserts judges’ minimum standards of procedural fairness—most importantly, how minor witnesses were dealt with and evidence was gathered—as essential to a fair trial. The judgment embodies judicial restraint coupled with a guarantee of substantive justice under Article 136.
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WRITTEN BY ADI MEHTA
