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Esakkimuthu v. State represented by the Inspector of Police

Criminal Appeal · 2025 INSC 880Decided 22 Jul 2025
Crl.A. No.-003099-003099 - 2025 (arising out of SLP(Crl) No. 1693 of 2025, heard with the connected appeal of Pitchu Mani @ Pitchai Mani, SLP(Crl) No. 3816 of 2025)
Justice Vikram Nath · Justice Sandeep Mehta

Background

The appellant (Accused No. 2) and a co-accused, Pitchu Mani (Accused No. 1), were convicted by a trial court and had that conviction upheld by the Madras High Court for the 2013 murder of one Edison Suvisedha Muthu, allegedly motivated by an old enmity between the deceased and Accused No. 1's father. The prosecution's case rested mainly on the deceased's son and wife (PW-1 and PW-2), who claimed to have followed the deceased on a bicycle to a liquor shop and personally witnessed the appellant luring the deceased there before the co-accused arrived and fatally attacked him. Several other alleged eyewitnesses present at the liquor shop, including its manager and other customers, were declared hostile and did not support the prosecution's version, instead describing an attack by four or five persons. Both convicted men appealed to the Supreme Court challenging the reliability of the eyewitness evidence.

Decision Breakdown

The Supreme Court found the prosecution's core eyewitness story implausible: PW-1 and PW-2 claimed to have cycled roughly 16 kilometers to the liquor shop in under thirty minutes to arrive in time to witness the murder, which the Court found physically improbable and undermining of their claimed presence at the scene. It also found it suspicious that after witnessing the murder, the two star witnesses travelled the entire distance back home before going to a police station, even though a police station lay en route, with no satisfactory explanation offered. Compounding this, the post-mortem recorded 26 injuries on the deceased, more consistent with an attack by multiple assailants (as described by the hostile witnesses) than by the two accused alone, and the deceased, a habitual drunkard with a criminal history under the Goondas Act, plausibly had enmities with several people. Concluding that the prosecution had not proved guilt beyond reasonable doubt and that genuine doubt existed about whether the accused were even present at the crime scene, the Court set aside both the High Court and trial court judgments, acquitted both appellants, and ordered their release unless wanted in any other case.

Lesson Learnt

A murder conviction cannot stand on eyewitness testimony that is physically implausible or leaves unexplained gaps in conduct (such as bypassing a nearby police station); when the surrounding facts, including the nature and number of injuries, point to a different, more probable explanation, courts must give the accused the benefit of reasonable doubt rather than convict on a shaky prosecution narrative.

Official source (sci.gov.in)View Judgment (PDF)

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