Thammaraya vs. State of Karnataka, Criminal Appeal No. 649 of 2013, Supreme Court of India, Judgment dated January 22, 2025, [2025 INSC 108]
- ByPravleen Kaur --
- 15 Jun 2025 --
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The Supreme Court of India in Thammaraya vs. State of Karnataka [Criminal Appeal No. 649 of 2013, decided January 22, 2025; 2025 INSC 108] acquitted the appellants in a 24-year-old murder case, highlighting critical lapses in the prosecution’s investigation and the importance of rigorous evidentiary standards in cases based on circumstantial evidence.
Facts and Background
The case involved Thammaraya (A-2) and Basappa @ Basavaraj (A-3), who, along with Manoj (now deceased), were accused of murdering Shrishail, a liquor merchant. The prosecution alleged that Manoj, motivated by a troubled relationship with Shrishail’s wife, lured Shrishail under the pretense of seeking medical help. Manoj, along with the appellants, allegedly strangled Shrishail, stripped him, and abandoned his body. Manoj initially reported the incident to the police as an attack by unknown assailants, but inconsistencies in his narrative led to his confession and the implication of the appellants as accomplices.
Legal Issues
The reliability of disclosure statements and recovery of looted items as evidence.
The necessity and conduct of a Test Identification Parade (TIP) in cases hinging on circumstantial evidence.
The standard of proof required for conviction in murder cases based on indirect evidence.
Supreme Court’s Findings
The Supreme Court, comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta, found significant flaws in the prosecution’s case. The Court observed that the investigation suffered from “sheer negligence and dereliction of duty” by both the Investigating Agency and the Public Prosecutor, particularly for failing to conduct a Test Identification Parade (TIP), which is crucial when eyewitness identification is in question.
The Court noted that the disclosure statements and the recovery of allegedly looted items were not corroborated by independent evidence. The prosecution’s reliance on these weak links, without proper identification and corroboration, was deemed insufficient to establish guilt beyond reasonable doubt. The Court reiterated that in cases based on circumstantial evidence, every link in the chain must be proven, and any missing or weak link entitles the accused to acquittal.
Conclusion
The Supreme Court acquitted Thammaraya and Basappa, holding that the prosecution failed to prove its case beyond reasonable doubt due to investigative lapses and lack of credible evidence.
The judgment underscores the necessity of conducting TIPs and the importance of corroborative evidence in circumstantial cases.
The decision serves as a cautionary precedent on the responsibilities of investigative agencies and prosecutors in ensuring fair trials and upholding the rights of the accused.
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