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Criminal LawSupreme Court of India

Murugan v. The State of Tamil Nadu

Criminal Appeal · 2018 INSC 440Decided 2 May 2018
Criminal Appeal No. 1498 of 2010
Justice R.K. Agrawal · Justice Abhay Manohar Sapre

Background

A man named Kumar wanted to marry a schoolgirl, Geetha, against the wishes of her father, also named Murugan (the appellant was Kumar's cousin, also named Murugan, a different person from Geetha's father). Kumar and the appellant invited Geetha's father for dinner at Kumar's house one night, and Geetha's father was found dead the next morning from multiple injuries after being last seen dining with the two men. Kumar died before the trial could be completed, and the case continued only against the cousin, who was convicted by the trial court and the High Court.

Decision Breakdown

The Supreme Court held that the concurrent findings of the two courts below were legally and factually sound, based on an unbroken chain of circumstances: the motive (Kumar's thwarted wish to marry the victim's daughter), the appellant's close association with Kumar, their joint visit to invite the victim, the dinner together, the victim's death occurring shortly after, and the appellant's complete failure to explain these circumstances when questioned. The Court rejected the argument that Kumar's death before trial meant nothing survived against the appellant, holding that the case was one of common intention between the two men to eliminate the victim and that the appellant's own conduct and the "last seen together" circumstance were sufficient to sustain his conviction independently. The appeal was dismissed and the conviction and life sentence upheld.

Lesson Learnt

Being the last person seen in the company of a victim shortly before death is a strong circumstance against an accused, and the death of a co-accused before trial does not automatically benefit a surviving accused where the evidence independently establishes his own participation in a common plan.

Murugan v. The State of Tamil Nadu – Legal Case Shots | LegalAware