D.Duraiyarasan vs The Inspector Of Police on 21 April, 2026

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    Madras High Court

    D.Duraiyarasan vs The Inspector Of Police on 21 April, 2026

    Author: N.Anand Venkatesh

    Bench: N.Anand Venkatesh

                                                                                 CRL.A(MD).No.779 of 2023
    
    
    
    
                                 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
    
                                                      Dated : 21.04.2026
    
                                                          CORAM :
    
                                THE HONOURABLE MR.JUSTICE N.ANAND VENKATESH
                                                   AND
                                THE HONOURABLE MR.JUSTICE K.K.RAMAKRISHNAN
    
                                                CRL.A(MD).No.779 of 2023
                                                         and
                                               CRL MP(MD).No.15194 of 2023
    
                         D.Duraiyarasan                                          ... Appellant
    
    
                                                            Vs.
                         The State rep by its,
                         The Inspector of Police,
                         Srivilliputhur Town Police Station,
                         Srivilliputhur, Virudhunagar District.
                         (Crime No.101 of 2014)                                  ... Respondent
    
                         PRAYER : Criminal Appeal is filed under Section 374(2) of the Criminal
                         Procedure Code, to call for the records and set aside the judgment dated
                         26.07.2023 made in S.C.No.61 of 2015 on the file of the learned Sessions
                         Judge, Fast Track Mahila Court, Srivilliputhur and allow the criminal
                         appeal.
    
    
    
    
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                                                                                       CRL.A(MD).No.779 of 2023
    
    
                                      For Appellant      : Mr.C.Christopher for
                                                           Mr.A.Padmanaban
    
                                      For Respondent     : Mr.A.Thiruvadi Kumar
                                                           Additional Public Prosecutor
    
                                                        JUDGMENT
    

    (Judgment of the Court was made by K.K.RAMAKRISHNAN,J.)

    The sole accused in S.C.No.61 of 2015, on the file of the learned

    SPONSORED

    Sessions Judge, Fast Track Mahila Court, Srivilliputhur has preferred the

    present appeal challenging the conviction and sentence imposed upon him

    under Section 450 of IPC sentencing him to undergo 10 years Rigorous

    Imprisonment and to pay fine of Rs.2000/- indefault, to undergo 3 months

    Rigorous imprisonment and convicting him under Section 302(2 counts) of

    IPC and sentencing him to undergo life imprisonment and fine of Rs.5,000/-

    in default, to undergo 6 months Rigorous imprisonment (2 counts) and

    convicting him under Sections 404 of IPC and sentencing him to undergo 3

    months Rigorous imprisonment and to pay fine of Rs.1000/- indefault to

    undergo 3 months Rigorous imprisonment and convicting him under

    Section 380 of IPC and sentencing him to undergo 7 years Rigorous

    imprisonment and to pay fine of Rs.3000/- indefault, to undergo three

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    months Rigorous imprisonment and directing the sentences to concurrently,

    as per the judgment dated 26.07.2023.

    2.Brief facts of the case:

    According to the prosecution, the deceased, namely Saroja (D1),

    was a retired Office Assistant in the Panchayat Union, and her husband

    Solaimalai (D2) was employed as a teacher in a private Higher Secondary

    School at Srivilliputhur. The couple resided at Soundiamman Koil Street,

    Srivilliputhur and had no children. PW1, the sister of D1, and PW4, her

    husband, were residing separately. On 17.02.2014 at about 9:30 a.m., PW1

    tried to contact the deceased over phone, but there was no response.

    Suspecting something foul, PW1, along with PW4 and other relatives, went

    to the house of the deceased at about 5:15 p.m. On entering the house, they

    were shocked to see both D1 and D2 lying dead with severe head injuries.

    PW1 lodged a complaint before the respondent police, upon which a case in

    Crime No.101 of 2014 was registered under Sections 450 and 302 of the

    Indian Penal Code. The First Information Report was marked as Ex.P14.

    PW20, the Inspector of Police, took up the investigation, visited the scene

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    of occurrence, and prepared the Observation Mahazar and Rough Sketch

    (Exhibits.P8 and P15) in the presence of witnesses. He also seized material

    objects including bloodstained earth and a grinder stone alleged to have

    been used for the commission of the offence.

    2.1.Inquest was conducted over the bodies of both deceased

    (Exs.P16 and P17), and the bodies were sent for postmortem. PW14, the

    Doctor, conducted autopsy on 18.02.2014 and opined that the deaths were

    due to head injuries sustained, and that the time of death was approximately

    32 to 46 hours prior to postmortem.

    2.2.On 24.02.2014, the accused allegedly appeared before the

    Village Administrative Officer (VAO) and gave an extra-judicial confession,

    which was recorded as Ex.P15. In the said confession, the accused is stated

    to have admitted that he committed the murder due to a monetary dispute, as

    the D1 had failed to give him money. He further stated that when D2

    intervened, he assaulted him also with a grinder stone and he had stolen and

    sold of gold jewels belonged to the deceased.

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    2.3.Pursuant to the said confession, recoveries were effected

    under Section 27 of the Indian Evidence Act, including bloodstained clothes

    (MOs 13 and 14).

    2.4.Based on his disclosure, part of the jewels were traced through

    one Sheikh Alavuddin and subsequently in a jewellery shop, where they had

    been melted into gold bars. Some more jewels (MOs 2 to 11) were

    recovered from a scrap shop identified by the accused. Investigating agency

    examined material witnesses and collected FSL report and after completing

    investigation, final report was filed before the jurisdictional Magistrate,

    namely the Judicial Magistrate No.II, Srivilliputhur, and the same was taken

    on file in P.R.C.No.38 of 2014. Thereafter, the case was committed to the

    Mahila Special Court, Srivilliputhur, and was taken on file as S.C. No.61 of

    2015.

    2.5.The accused was summoned and, upon appearance when he

    was questioned, he pleaded not guilty and claimed to be tried. The learned

    trial Judge framed the necessary charges under Sections 450, 302 (two

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    counts), 404, and 380 IPC against the appellant. The accused denied the

    charges and claimed to be tried. In order to prove its case, the prosecution

    examined PWs 1 to 20, marked Exs. P1 to P23, and produced MOs 1 to 20.

    Thereafter, the learned trial Judge examined the accused under Section 313

    of Cr.P.C asking him about the incriminating circumstances appearing in the

    evidence on record. The accused denied the same as false. On the side of the

    defence, RW1 and RW2 were examined.

    2.6.The learned trial Judge, after considering the entire evidence

    and materials on record, found the accused guilty of the offences charged,

    and sentenced him as stated above, by judgment dated 26.07.2023.

    Challenging the same, the present appeal has been filed by the

    accused/appellant.

    3. Submissions of the learned counsel appearing for the

    appellant:

    The learned Counsel for the appellant would submit that this is a

    case based entirely on circumstantial evidence. He would further contend

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    that the principles laid down by the Hon’ble Supreme Court for appreciating

    circumstantial evidence have not been followed by the trial court, and the

    prosecution has failed to prove the case beyond reasonable doubt.

    3.1.According to the learned counsel for appellant, in a case of

    circumstantial evidence, the prosecution must establish a complete chain of

    circumstances, each of which must be proved beyond reasonable doubt, and

    the circumstances must be consistent with the hypothesis of guilt of

    accused, that is to say, they should not be explained on any other hypothesis

    except that the accused is guilty. In the present case, none of these principles

    have been properly considered by the learned trial Judge.

    3.2.The learned trial Judge relied upon the evidence of PW9, who

    stated that D2 had informed him on 16.02.2014 about the visit of the

    accused to their house and that the accused had demanded money and

    property from them since they had no children. However, apart from this

    statement, there is no other evidence available on record to show that the

    accused was present in the house at the time of occurrence or was seen in

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    the company of the deceased at any point of time prior to their death.

    Therefore, the “last seen” theory has not been established. The evidence of

    PW9 is purely hearsay and cannot be relied upon.

    3.3.The learned trial Judge also relied upon the extra-judicial

    confession said to have been given by the accused before the Village

    Administrative Officer. It is highly improbable that the accused, who hails

    from Tiruvarur District, would travel more than 300 kilometers and give a

    confession before an unknown Village Administrative Officer after several

    days from the date of occurrence. Hence, the extra-judicial confession is

    inherently improbable and unreliable. It is further submitted that extra-

    judicial confession is a weak piece of evidence, and in the absence of

    corroboration, the conviction cannot be sustained solely on that basis and

    placed reliance of the judgement of the Supreme Court in the case of

    Chandrapal vs State of Chhattisgargh reported in (2023) 16 SCC 655.

    3.4.The learned counsel further submitted that there is no

    corroboration for the contents of the alleged extra-judicial confession, and

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    therefore, the conviction based on such evidence is unsustainable.

    3.5.With regard to the recovery of jewels, the learned trial Judge

    failed to consider that the recovery has not been proved in accordance with

    law. There is no evidence available on record to show that the jewels

    belonged to the deceased or that the accused had committed theft of the

    same. The evidence of PW7, the Village Administrative Officer, and other

    witnesses (PWs 10, 11, 12, and 13) is not reliable to prove the source and

    manner of recovery. The recoveries appear to have been a made up story to

    falsely implicate the accused.

    3.6.It is further submitted that the fingerprint expert’s evidence is

    also unreliable. There is no material to show when and how the fingerprints

    of the accused were taken. No document has been produced to establish that

    the specimen fingerprints were obtained in accordance with law and

    forwarded for comparison. The fingerprint expert submitted his report on

    17.02.2016, whereas the accused was arrested only on 24.02.2016. Even on

    the date of arrest, there is no evidence to show that his fingerprints were

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    taken. Therefore, the opinion of the fingerprint expert is of no help to the

    prosecution and has not been properly appreciated by the trial court.

    3.7.It is also stated that four sets of fingerprints were marked,

    namely: one relating to D1, another to D2, one to a person by name, Arul

    Kumar, and one allegedly to the accused. However, in the absence of proper

    proof regarding the collection and comparison of fingerprints, the said

    evidence cannot be relied upon.

    3.8.The learned counsel for the appellant would further submit

    that the alleged recovery of bloodstained clothes is doubtful. According to

    him, the bloodstained clothes were not recovered from the deceased, and the

    recovery mahazar does not disclose that the accused’s clothes were

    recovered in the manner alleged by the prosecution. A perusal of Ex.P11

    would show that the recovery was effected in the presence of police

    officials. Therefore, the claim of the prosecution that the recovery was made

    in the presence of the Village Administrative Officer is not believable. It is

    further contended that the prosecution has failed to prove its case beyond

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    reasonable doubt looking from all angles.

    3.9.The learned counsel would also submit that the prosecution

    story is inherently improbable. According to the prosecution, the accused

    used a heavy grinder stone weighing approximately 11 kilograms to assault

    the deceased on the head. However, the medical evidence does not disclose

    injuries consistent with such a brutal assault, such as complete crushing or

    extensive damage to the skull. Therefore, the version of the prosecution that

    such a heavy object was used without causing relatively fatal injuries is

    highly unbelievable.

    3.10.The learned counsel further submitted that, as per the

    prosecution case, the accused handed over the stolen jewels to one Sheikh

    Alavudeen, who in turn passed them on to PW10, and thereafter the jewels

    were taken to PW13, a jeweller, who allegedly converted them into gold

    bars. However, the evidence of PW13 does not inspire confidence. More

    importantly, the said Sheikh Alavudeen, who is a crucial link in the chain of

    circumstances, has not been examined. This omission is fatal to the

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    prosecution case.

    3.11.With regard to the recovery of jewels allegedly belonging to

    the deceased, it is submitted that the evidence of PWs 10, 11, 12, and 13 are

    unreliable and appears to be stage-managed. It is further contended that the

    recovery proceedings were fabricated even prior to the arrest of the accused.

    There are material contradictions between the evidence of PW15 (Village

    Administrative Officer) and the Investigating Officer. While the

    Investigating Officer stated that the confession was recorded at one place

    and recovery was effected at another place PW5, a material witness,

    deposed that the confession was recorded in a shop and the recovery was

    made pursuant thereto. These material contradictions strike at the root of the

    prosecution case and create serious doubt.

    3.12.The learned counsel also pointed out that one of the

    fingerprints (marked as M3) was identified as belonging to one Arul Kumar.

    The prosecution has failed to explain the presence of this fingerprint at the

    scene of occurrence. No investigation has been conducted to trace or

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    examine the said Arul Kumar. This lapse on the part of the prosecution

    suggests suppression of material facts and possible involvement of some

    other persons.

    3.13.In view of these serious infirmities, it is submitted that the

    prosecution has failed to establish the guilt of the accused beyond

    reasonable doubt, and therefore, the appellant is entitled to acquittal.

    4. Submissions of the learned Additional Public Prosecutor:

    Per contra, the learned Additional Public Prosecutor, upon perusal

    of the records and the impugned judgment, and with the assistance of the

    investigating officer present before the Court, would submit that this is a

    case of double murder, and the prosecution has established its case through

    cogent and convincing circumstantial evidence. It is contended that the

    evidence of P.W.6 and P.W.9 clearly establishes the involvement of the

    accused. The recovery of incriminating materials, including the jewels

    belonging to the deceased, has been duly proved. The minor contradictions

    pointed out by the defence do not go to the root of the matter and are not

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    sufficient to discard the prosecution case.

    4.1.The learned Additional Public Prosecutor would further

    submit that the recovery of the stolen jewels, coupled with the failure of the

    accused to offer a plausible explanation under Section 313 of Cr.P.C., forms

    a strong incriminating circumstance against him. Taken cumulatively, these

    circumstances establish the guilt of the accused beyond reasonable doubt.

    Therefore, he seeks to dismiss this appeal.

    5. This Court considered the rival submissions made by the

    learned counsel appearing for the appellant and the learned Additional

    Public Prosecutor appearing for the respondent and perused the materials

    available on record and the precedents relied upon by them.

    6.The question arises in this case are as follows:

    i) Whether the prosecution proved the case beyond reasonable

    doubt against the appellant and consequently conviction and sentence

    passed against the appellant in S.C.No.61 of 2015 can be sustained?

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    7.Discussion on the legal principles:

    Before discussing this case on merits, this Court would like to

    extract the principle laid down by the Hon’ble Supreme Court on the nature

    and essential proof required in a criminal case which rests on circumstantial

    evidence.

    7.1.The foundational decision of the Hon’ble Supreme Court in

    the case of the circumstantial evidence is Hanumant v. State of Madhya

    Pradesh [(1952) 2 SCC 71 and the relevant portion of the judgement is

    extracted hereunder:

    “It is well to remember that in cases where the
    evidence is of a circumstantial nature, the circumstances
    from which the conclusion of guilt is to be drawn should
    in the first instance be fully established, and all the facts
    so established should be consistent only with the
    hypothesis of the guilt of the accused. Again, the
    circumstances should be of a conclusive nature and
    tendency and they should be such as to exclude every
    hypothesis but the one proposed to be proved. In other

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    words, there must be a chain of evidence so far complete
    as not to leave any reasonable ground for a conclusion
    consistent with the innocence of the accused and it must
    be such as to show that within all human probability the
    act must have been done by the accused.”

    7.2.Yet another judgement of the Hon’ble Constitution Bench of

    Supreme Court is In M.G. Agarwal vs State of Maharashtra [AIR 1963 SC

    200 and the Hon’ble Constitution Bench held as follows:

    If the circumstances proved in a case are
    consistent either with the innocence of the accused, or with
    his guilt, then the accused is entitled to the benefit of doubt.
    When it is held that a certain fact has been proved, then the
    question that arises is whether such a fact leads to the
    inference of guilt on the part of the accused person or not,
    and in dealing with this aspect of the problem, benefit of
    doubt must be given to the accused, and a final inference of
    guilt against him must be drawn only if the proved fact is
    wholly inconsistent with the innocence of the accused, and
    is entirely consistent with his guilt.

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    7.3.The Hon’ble three judges Bench of the Hon’ble Supreme Court

    in the case of Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4

    SCC 116 153 set out five golden principles, namely the panchsheel of the

    proof of a case based on circumstantial evidence and the same is as follows:

    (1) the circumstances from which the conclusion of guilt is to
    be drawn should be fully established.

    7.3.1. It may be noted here that this Court indicated
    that the circumstances concerned “must or should” and not
    “may be” established. There is not only a grammatical but a
    legal distinction between “may be proved” and “must be or
    should be proved” as was held by this Court in the case of
    Shivaji Sahabrao Bobade v. State of Maharashtra reported in
    (1973) 2 SCC 793, which reads as follows:

    “Certainly, it is a primary principle that the accused must
    be and not merely may be guilty before a court can convict and
    the mental distance between ‘may be’ and ‘must be’ is long and
    divides vague conjectures from sure conclusions.”
    7.3.2. the facts so established should be consistent
    only with the hypothesis of the guilt of the accused, that is to
    say, they should not be explainable on any other hypothesis
    except that the accused is guilty,
    7.3.3. the circumstances should be of a conclusive
    nature and tendency,

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    7.3.4. they should exclude every possible hypothesis
    except the one to be proved, and
    7.3.5. there must be a chain of evidence so complete
    as not to leave any reasonable ground for the conclusion
    consistent with the innocence of the accused and must show
    that in all human probability the act must have been done by
    the accused.

    7.4. In the case of Padala Veera Reddy v. State of A.P. reported in

    1989 Supp (2) SCC 706, it was laid down that when a case rests upon

    circumstantial evidence, such evidence must satisfy the following tests:

    “(1) the circumstances from which an inference of guilt is
    sought to be drawn, must be cogently and firmly established;
    (2) those circumstances should be of a definite tendency
    unerringly pointing towards guilt of the accused;
    (3) the circumstances, taken cumulatively, should form a
    chain so complete that there is no escape from the conclusion
    that within all human probability the crime was committed by
    the accused and none else; and
    (4) the circumstantial evidence in order to sustain conviction
    must be complete and incapable of explanation of any other
    hypothesis than that of the guilt of the accused and such
    evidence should not only be consistent with the guilt of the
    accused but should be inconsistent with his innocence.”

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    7.5. Hon’ble Supreme Court also reiterated the said principles in

    the case of C. Chenga Reddy v. State of A.P. reported in (1996) 10 SCC

    193 wherein it has been observed thus :

    “21. In a case based on circumstantial evidence,
    the settled law is that the circumstances from which the
    conclusion of guilt is drawn should be fully proved and such
    circumstances must be conclusive in nature. Moreover, all
    the circumstances should be complete and there should be
    no gap left in the chain of evidence. Further, the proved
    circumstances must be consistent only with the hypothesis of
    the guilt of the accused and totally inconsistent with his
    innocence.”

    7.6. It is well settled principle that “fouler the crime higher the

    proof” and the suspicion, however great it may be, cannot take the place of

    legal proof and the Hon’ble Supreme Court has reiterated the said principle

    in the following cases:

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    7.6.1. In the case of Sujit Biswas v. State of Assam, in (2014) 1

    SCC (Cri) 677, the Hon’ble Supreme Court has held as follows:

    13. Suspicion, however grave it may be, cannot
    take the place of proof, and there is a large difference
    between something that “may be” proved, and something
    that “will be proved”. In a criminal trial, suspicion no matter
    how strong, cannot and must not be permitted to take place of
    proof. This is for the reason that the mental distance between
    “may be” and “must be” is quite large, and divides vague
    conjectures from sure conclusions. In a criminal case, the
    court has a duty to ensure that mere conjectures or suspicion
    do not take the place of legal proof. The large distance
    between “may be” true and “must be” true, must be covered
    by way of clear, cogent and unimpeachable evidence
    produced by the prosecution, before an accused is
    condemned as a convict, and the basic and golden rule must
    be applied. In such cases, while keeping in mind the distance
    between “may be” true and “must be” true, the court must
    maintain the vital distance between mere conjectures and
    sure conclusions to be arrived at, on the touchstone of
    dispassionate judicial scrutiny, based upon a complete and
    comprehensive appreciation of all features of the case, as
    well as the quality and credibility of the evidence brought on
    record. The court must ensure, that miscarriage of justice is

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    avoided, and if the facts and circumstances of a case so
    demand, then the benefit of doubt must be given to the
    accused, keeping in mind that a reasonable doubt is not an
    imaginary, trivial or a merely probable doubt, but a fair
    doubt that is based upon reason and common sense.

    7.7. In the case of circumstantial evidence, the judgment remains

    essentially inferential. The famous Author “Sri Alfred Wills, in his

    admirable book “Wills’ Circumstantial evidence” laid rules to draw such

    legal inference which has been followed and observed as universal guide by

    various Courts all over world including our Apex Court in the case of

    Geejaganda Somaiah v. State of Karnataka, reported in (2007) 9 SCC 315

    which reads as follows:

    7.7.(A). The facts alleged as the basis of any legal
    inference must be clearly proved and beyond reasonable doubt
    connected with the factum probandum;

    7.7.(B). The burden of proof is always on the party
    who asserts the existence of any fact, which infers legal
    accountability;

    7.7.(C). In all cases, whether of direct or
    circumstantial evidence the best evidence must be adduced

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    which the nature of the case admits;

    7.7.(D). In order to justify the inference of guilt, the
    inculpatory facts must be incompatible with the innocence of
    the accused and incapable of explanation, upon any other
    reasonable hypothesis than that of his guilt; and
    7.7.(E). If there be any reasonable doubt of the guilt
    of the accused, he is entitled as of right to be acquitted.

    7.8. The Hon’ble Supreme Court in the case of Sujit Biswas v.

    State of Assam, reported in 2014 (1) SCC (Cri) 677 has followed similar

    line of guidance in paragraph No.18 which reads as follows:

    18….. In a case of circumstantial evidence, the
    judgment remains essentially inferential. Inferences are drawn
    from established facts, as the circumstances lead to particular
    inferences. The court must draw an inference with respect to
    whether the chain of circumstances is complete, and when the
    circumstances therein are collectively considered, the same must
    lead only to the irresistible conclusion, that the accused alone is
    the perpetrator of the crime in question. All the circumstances so
    established must be of a conclusive nature, and consistent only
    with the hypothesis of the guilt of the accused.

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    7.9. This case rests entirely on circumstantial evidence.

    Therefore, from the above principles laid down by the Hon’ble Supreme

    Court, the following principles flows:

    Firstly, the prosecution must prove each link in
    the chain of circumstances beyond reasonable doubt.

    Secondly, all the circumstances so proved must
    form a complete chain, excluding every other possible
    hypothesis except that of the guilt of the accused.

    Thirdly, the circumstances must be of a
    conclusive nature and tendency. It is also the duty of the
    Court to ensure that the facts so established are consistent
    only with the hypothesis of the guilt of the accused and not
    with any other hypothesis.

    7.10. Keeping these settled principles in mind, this Court proceeds

    to examine the facts of the present case.

    8.Discussion on the recovery:

    According to the prosecution, based on the extra-judicial

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    confession, the accused had stolen two gold chains belonging to deceased

    Nos. 1 and 2. To prove this allegation, the prosecution relied upon the arrest

    and recovery said to have been effected on 24.02.2014. It is alleged that,

    after the extra-judicial confession, the accused gave another confession to

    the Investigating Officer (PW20), and on the basis of the disclosure

    statement marked as Ex.P27, recovery was effected under Ex.P18.

    8.1.The prosecution case is that there were two categories of

    jewellery. First, certain jewels were pledged with a shop owner. Secondly,

    according to the second confession of the accused, he had stolen several

    items of jewellery from the deceased. Among those items, he allegedly

    handed over two gold chains belonging to deceased No.1 to one Sheikh

    Allaudin, who has not been examined before this Court. It is further stated

    that the said Sheikh Allaudin, in turn, handed over the chains to another

    person, and ultimately the accused went to a shop where the chains were

    melted into gold ingots, which were later recovered. The remaining

    jewellery items, marked as M.O. Nos. 2 to 11, were also recovered based on

    the confession of the accused.

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    8.2.However, there is a material contradiction between the

    evidence of the Investigating Officer and that of the recovery witness. The

    Investigating Officer deposed that the confession was recorded at the police

    station, whereas the Village Administrative Officer, who attested the

    recovery mahazar, specifically stated that the confession was recorded at the

    place of recovery, which is more than 300 kilometers away from the police

    station.

    8.3.Further, one of the material circumstances relates to the

    alleged recovery of bangles belonging to the deceased. However, the

    photographs marked by the prosecution clearly show that the bangles were

    found on the body of D1. In such circumstances, the recovery appears to be

    doubtful. Therefore, it is contended that the entire recovery has been

    fabricated by the prosecution in order to support the extra-judicial

    confession.

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    9.Discussion on extra judicial confession:

    The Hon’ble supreme Court in the following cases reiterated the

    principle that an extra-judicial confession is a weak piece of evidence and

    must be examined with great care and caution and It must be shown to have

    been made voluntarily, must be truthful, and must inspire confidence.

    9.1.In the case of Chandrapal vs State of Chhattisgargh reported

    in (2023) 16 SCC 655. The Hon’ble Supreme Court held as follows:

    ”19. In Sahadevan vs State of T.N. it was
    observed in Para 14 as under:

    ”14. It is settled principle of criminal
    jurisprudence that extra-judicial confession is a weak piece
    of evidence. Wherever the Court, upon due appreciation of
    the entire prosecution evidence, intends to base a
    conviction on an extra-judicial confession, it must ensure
    that the same inspires confidence and is corroborated by
    other prosecution evidence. If, however, the extra-judicial
    confession suffers from material discrepancies or inherent
    improbabilities and does not appear to be cogent as per the
    prosecution version, it may be difficult for the court to base
    a conviction on such a confession. In such circumstances,

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    the Court would be fully justified in ruling such evidence
    out of consideration.”

    20. The said ratio was also reiterated and
    followed by this Court in Jagroop Singh vs State of Punjab,
    Sk.Yusuf vs State of W.B. And Pancho vs State of Haryana,
    wherein it has been specifically laid down that the extra-

    judicial confession is a weak evidence by itself and it has to
    be examined by the Court with greater care and caution. It
    should be truthful and should inspire confidence. An extra-
    judicial confession attains greater credibility and
    evidentiary value if it is supported by chain of cogent
    circumstances and is further corroborated by other
    prosecution evidence.”

    10. In this case, the accused came to P.W.15’s office on

    24.02.2016 at 09.00a.m. in the presence of his assistant namely Sivan and

    gave the voluntary extra-judicial confession admitting his guilt. The said

    Sivan was not examined to corroborate the above P.W.5 evidence. Accused

    in his 313 Cr.P.C. stated that on 22.02.2014, the police officials came to his

    native place at Thiruvarur, and forcibly obtained his fingerprints by

    subjecting him to coercion, including physical force. He has also stated that

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    the alleged confession was obtained under duress and that no recovery was

    effected in the manner alleged by the prosecution. It is well settled that the

    Court is duty-bound to consider the explanation offered by the accused

    under section 313 Cr.P.C. in the light of the evidence on record. However,

    this explanation offered by the accused has not been considered by the

    learned trial Judge in his discussion. There is no reference whatsoever to the

    said explanation in the judgment. D.W.1, Revenue Inspector, Srivilliputhur

    was examined and he was requested to produce the movement register of

    P.W.15. It is the case of the prosecution that P.W.15 after recording the

    extra-judicial confession went to the accused village Thiruvarur. But, D.W.

    1 specifically deposed that there was no record available to show that on

    24.02.2014, P.W.15 went to Thiruvarur. It is also clear from the records that

    the distance between the Thiruvarur and the Srivilliputhur is more than 300

    Kms. Therefore, this Court inclines to accept the argument of the learned

    Counsel for the appellant that it is highly improbable that the accused, who

    hails from Tiruvarur District, would travel more than 300 kilometers and

    give a confession before an unknown Village Administrative Officer after

    several days from the date of occurrence.

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    11. Accordingly, in view of the above inherent improbabilities

    attached with the above extra-judicial confession and the explanation

    furnished by the accused appears to be plausible and the failure of the trial

    Court to consider the explanation would result into finding that the extra-

    judicial confession is inherently improbable, unreliable and does not inspire

    confidence, the conviction passed against the appellant on the basis of the

    extra-judicial confession is not legally correct.

    12. Discussion on last seen theory:

    P.W.9 was examined to prove the last seen theory. Admittedly, he

    was not direct witness to prove the last seen theory. He deposed that D.2

    had informed him on 16.02.2014 about the visit of the accused to his house.

    Apart from that, there is no other evidence available on record to show that

    accused was present in the house of the deceased at the time of the

    occurrence or was seen in the company of the deceased at any point of time

    prior to the death. Therefore, this Court holds that prosecution miserably

    failed to prove the last seen theory.

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    13.Discussion on the finger print expert:

    13.1. It is well settled that unless the prosecution proves that the

    specimen fingerprints of the accused were obtained in a manner known to

    law and properly compared, such evidence cannot be relied upon. It is

    relevant to refer the judgement of Division Bench of this Court in the case

    of Arumugam and another vs State represented by Inspector of Police,

    Kottapatti Police Station, Dharmapuri District reported in (2024) 3 MLJ

    (crl) 491, and the relevant portion of the said judgement is extracted as

    follows:

    ”(iii) It is well settled that the evidence of a fingerprint
    expert is not a substantive evidence and it can only corroborate the
    other evidence on record. However, as to what value could be
    attached to a report given by a police officer, who claims to be
    trained in fingerprint comparison, even for the purpose of
    corroboration, would depend upon the facts and circumstances of
    each case.

    Therefore, in the absence of any definite evidence as to whether

    specimen fingerprints of the accused were taken and sent to the Fingerprint

    Bureau, the comparison would not be relevant, and it would be difficult to

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    place reliance on such a report.”

    14. In this case, to implicate the accused, the prosecution rest

    upon the alleged presence of his fingerprints at the scene of occurrence.

    According to the fingerprint expert (PW17), four chance prints were lifted,

    marked as M1, M2, M3, and M4. Out of these, M1 was identified as

    belonging to deceased No.1, M2 to deceased No.2, M3 to one Arul Kumar,

    and M4 to the accused.

    15. According to the Investigating Officer, this constitutes one of

    the material links connecting the accused to the crime. However, no

    investigation whatsoever was conducted with regard to the presence of Arul

    Kumar’s fingerprint at the scene. The Investigating Officer has not

    furnished any explanation for exonerating Arul Kumar from the scope of

    investigation, despite the presence of his fingerprint. This omission assumes

    significance and casts a serious doubt on the fairness of the investigation.

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    16. Further, as per the prosecution, the accused was arrested only

    on 24.02.2014. However, the fingerprint expert is stated to have examined

    and given his opinion on 17.02.2014, which is prior to the arrest of the

    accused. In this context, no record has been produced by the prosecution to

    show as to how and when the specimen fingerprints of the accused were

    obtained.

    17. There is no material on record to establish that the fingerprints

    of the accused were taken in accordance with law prior to 17.02.2014. No

    document has been marked to show that permission was obtained under the

    Identification of Prisoners Act for taking the specimen fingerprints. Indeed,

    there is no scrap of evidence available to demonstrate that the fingerprints

    of the accused were collected as per law.

    18. Moreover, even in the expert opinion marked as an exhibit,

    there is no clear indication regarding the date on which the opinion was

    given or about the foundational data relied upon. In the absence of such

    foundational evidence, the opinion of the fingerprint expert becomes

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    doubtful.

    19. Further, fingerprint evidence, in the absence of corroborative

    circumstances, cannot by itself form the sole basis for conviction,

    particularly when the surrounding circumstances are doubtful and the

    possibility of involvement of other persons has not been ruled out.

    Therefore, the circumstances warrant applicability principle that when in the

    evidence two possibilities are available or open, one which goes in the

    favour of the prosecution and the other benefits the accused, the accused is

    undoubtedly entitled to the benefit of doubt and the same was fortified by

    the following judgement of the Hon’ble Supreme Court in the case of Kali

    Ram vs. State of H.P. reported in (1973) 2 SCC 808 and the Hon’ble

    Supreme Court has observed as under :

    “25. Another golden thread which runs through the
    web of the administration of justice in criminal cases is that if
    two views are possible on the evidence adduced in the case,
    one pointing to the guilt of the accused and the other to his
    innocence, the view which is favourable to the accused should
    be adopted. This principle has a special relevance in cases

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    wherein the guilt of the accused is sought to be established by
    circumstantial evidence.”

    19.1. In the case of State of U.P. vs. Ashok Kumar Srivastava

    reported in (1992) 2 SCC 86 it was pointed out that great care must be taken

    in evaluating circumstantial evidence and if the evidence relied on is

    reasonably capable of two inferences, the one in favour of the accused must

    be accepted. It was also pointed out that the circumstances relied upon must

    be found to have been fully established and the cumulative effect of all the

    facts so established must be consistent only with the hypothesis of guilt.

    20. In these circumstances, the alleged presence of the fingerprint

    of the accused cannot be safely relied upon and this Court holds that the

    conclusion reached by the learned trial judge on the basis of the fingerprint

    expert cannot be sustained.

    21.Discussion on the prosecution case of “Murder for gain”:

    The prosecution has projected the case as one of “murder for

    gain.” In such cases, it is incumbent upon the prosecution to establish,

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    beyond reasonable doubt, two essential facts: first, that the recovered

    articles belonged to the deceased; and second, that those very articles were

    stolen by the accused.

    21.1. In the present case, there is inconsistency with regard to the

    recovery of jewels as mentioned in the charge and the articles allegedly

    recovered under the recovery mahazar. The evidence of the recovery

    witnesses is not reliable, and the recovery itself has not been satisfactorily

    proved, particularly in light of the material contradictions between the

    testimony of the recovery witnesses and that of the Investigating Officer.

    21.2. Further, while the charge refers to six items of jewellery, the

    recovery under Ex.P11 speaks of more than eleven items. This unexplained

    discrepancy creates serious doubt regarding the genuineness of the recovery.

    In such circumstances, it appears that the investigating agency has

    attempted to introduce materials to artificially support the theory of “murder

    for gain.”

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    21.3. Moreover, even according to the prosecution, some of the

    articles were recovered from the bureau. The specific case of the

    prosecution is that the deceased refused to give money to the accused, and

    consequently, the accused hit the deceased with a grinder stone. In this

    context, there is no evidence to show that the bureau was broken open or

    that any key was used to open the bureau. No fingerprints were lifted from

    the bureau to connect the accused with the alleged theft.

    21.4. It is the duty of the prosecution to prove that the accused

    had stolen the articles of the deceased and without the same, chain would

    get smepped. It is relevant to refer the following observation of the Hon’ble

    Supreme Court in the case of Mohd. Aman and another vs State of

    Rajasthan reported in (1997) 10 SCC 44 which reads as follows:

    ”9. Unless the prosecution conclusively
    establishes that the articles recovered were stolen when
    the murder was committed, and not on an earlier
    occasion, there would be a missing link in the chain sofar
    as the specific accusation levelled against the accused is
    concerned.”.

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    21.5. But, in this case no material circumstances were established

    either to hold or infer the accused had stolen the articles of the deceased. In

    view of the said significant deficiencies, this Court finds it difficult to

    accept the prosecution’s version that the accused committed theft of the

    jewellery from the bureau or from the persons of the deceased and that the

    same was subsequently recovered at his instance.

    21.6. Accordingly, the material aspects of the prosecution case

    remain unproved, and the theory of “murder for gain” is not established

    beyond reasonable doubt.

    21.7. According to the prosecution, the complaint regarding the

    death of deceased Nos.1 and 2 was lodged by the sister of deceased No.1.

    However, in the said complaint, there is no reference whatsoever about the

    theft of any jewellery, or any allegation that the accused had stolen such

    jewels.

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    21.8. In these circumstances, the projection by the prosecution

    regarding recovery of jewels from the bureau, as well as the alleged

    recovery of jewels said to have been removed from the bodies of the

    deceased by the accused, appears to be dubious. As already discussed, this

    version appears to be made up story by the investigating agency to implicate

    the accused.

    22.Discussion on the blood stained clothes of the accused:

    Further, with regard to the recovery of the bloodstained clothes of

    the accused, the prosecution relies upon Ex.P7. However, Ex.P7 does not

    clearly relate to the accused. It is stated that M.O.Nos.13 and 14 were

    recovered in the presence of the Village Administrative Officer. On the other

    hand, the evidence of the police witnesses suggests that the recovery was

    effected in the presence of police constables. These constables are not

    independent witnesses, and this inconsistency further weakens the

    prosecution case.

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    22.1. Additionally, the forensic report (serology report) does not

    support or corroborate the prosecution version. In view of these

    discrepancies, the alleged recovery of the lungi and shirt, purportedly worn

    by the accused at the time of commission of offence, has not been proved

    beyond reasonable doubt.

    22.3. Therefore, in all respects, the prosecution has failed to prove

    the case beyond reasonable doubt, and the accused is entitled to benefit of

    doubt.

    23.Conclusion

    In light of the above circumstances, this Court finds that the

    prosecution has failed to establish its case beyond reasonable doubt on all

    material aspects. Merely because this is a case of double murder, the Court

    cannot be swayed by the gravity or the heinous nature of the offence in the

    absence of legally admissible and reliable evidence linking the accused to

    the crime. It is well settled principle that no conviction can be passed on

    mere suspicion and the same cannot amount to legal proof. In this regard, it

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    is relevant to extract the following judgement of the Hon’ble Supreme

    Court.

    Chandrakant Ganpat Sharad Birdhichand Sarda [Sharad
    Sovitkar vs. State of Birdhichand Sarda vs. State of
    Maharashtra, (1975) 3 SCC Maharashtra, (1984) 4 SCC 116
    16
    It is well settled that no one Graver the crime, greater should be the
    can be convicted on the basis standard of proof. An accused may
    of mere suspicion, however appear to be guilty on the basis of
    strong it may be. suspicion but that cannot amount to
    legal proof.

    24. Therefore, in view of the above discussion, the learned trial

    Judge has committed error in convicting the accused on suspicion alone

    which is not permissible in law.

    24.1. In the present case, the material on record indicates that the

    appellant has been implicated as an accused on the basis of an alleged extra-

    judicial confession and purported recoveries. These pieces of evidence do

    not inspire confidence and appear to be artificial in nature. It seems that the

    investigating agency, faced with the frustration of being unable to identify

    the true perpetrator of the crime, has resorted to constructing a case rather

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    than establishing proof of its commission through credible evidence. In this

    context it is apposite to refer the following portion of the judgment of the

    Hon’ble Supreme Court in the case of Prem Thakur v. State of Punjab,

    reported in (1982) 3 SCC 462 which reads as follows:

    11. …An a priori suspicion that the accused has
    committed the crime transforms itself into a facile belief that it is
    he who has committed the crime. Human mind plays that trick
    on proof of the commission of a crime by resisting the frustrating
    feeling that no one can be identified as the author of that crime.

    In the case before us, there is no doubt that five persons were
    murdered. Unquestionably, every effort had to be made to find
    out who committed those murders. But the duty is not done by
    holding someone or the other guilty somehow or the other….

    25. Accordingly, the Criminal Appeal is allowed on the following

    terms:

    25.1.The conviction and sentence imposed on the accused in

    S.C.No.61 of 2015 on the file of the learned Sessions Judge, Fast Track

    Mahila Court, Srivilliputhur dated 26.07.2023, is hereby set aside.

    25.2.The accused is acquitted of all charges and shall be released

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    forthwith, unless his presence is required in connection with any other case.

    25.3. If any fine amount, he paid, shall be refunded forthwith.

    Consequently, connected Criminal Miscellaneous Petition stands

    closed.

    
                                                                    [N.A.V, J.] & [K.K.R.K,J.]
                                                                               21.04.2026
                         NCC      :Yes/No
                         Index    :Yes/No
                         Internet :Yes/No
                         gvn/sbn
    
                         To:-
    
    

    1.The Sessions Judge, Fast Track Mahila Court,
    Srivilliputhur.

    2.The Inspector of Police,
    Srivilliputhur Town Police Station,
    Srivilliputhur,
    Virudhunagar District.

    3.The Additional Public Prosecutor,
    Madurai Bench of Madras High Court,
    Madurai.

    4. The Superintendent,
    Central Prison,
    Madurai.

    5.The Section Officer,
    Criminal Section (Records)
    Madurai Bench of Madras High Court, Madurai.

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    CRL.A(MD).No.779 of 2023

    N.ANAND VENKATESH, J.

    and
    K.K.RAMAKRISHNAN, J.

    gvn/sbn

    Judgment made in
    CRL.A(MD).No.779 of 2023

    Dated:21.04.2026

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