Summary of the Judgment: Kattavellai @ Devakar vs. State of Tamil Nadu
1. Heading of the Judgment
Case Title: Kattavellai @ Devakar vs. State of Tamil Nadu
Court: Supreme Court of India
Citation: 2025 INSC 845
Judges: Vikram Nath, Sanjay Karol, and Sandeep Mehta, JJ.
Date: July 15, 2025
2. Related Laws and Sections
The judgment revolves around the following legal provisions:
Indian Penal Code (IPC):
Section 302: Punishment for murder (dual counts for two victims).
Section 376: Punishment for rape.
Section 379: Punishment for theft.
Section 397: Robbery or dacoity with attempt to cause death or grievous hurt.Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989:
Section 3(2)(v): Enhanced punishment for offenses against SC/ST persons (not upheld).Indian Evidence Act, 1872:
Section 27: Admissibility of information leading to discovery of facts.
Section 106: Burden of proof for facts within accused’s knowledge.Code of Criminal Procedure (CrPC):
Section 366: Confirmation of death sentence by High Court.
3. Basic Judgment Details
Background: The appellant, Kattavellai @ Devakar, was convicted and sentenced to death by the Trial Court and High Court for the murder of two young victims (Ezhil Muthalvan and Kasturi) and the rape of Kasturi. The case relied entirely on circumstantial evidence.
Prosecution’s Case: The accused allegedly robbed and murdered the victims at Suruli Falls, Tamil Nadu, on May 14, 2011. Key evidence included last-seen testimony, DNA reports, recovery of stolen jewelry, and a confession statement.
Defense’s Argument: The defense challenged the reliability of witnesses, DNA evidence, and procedural lapses in investigation, including improper handling of forensic samples and lack of motive.
Supreme Court’s Ruling: The conviction was overturned due to insufficient evidence, procedural flaws, and failure to establish guilt beyond reasonable doubt.
4. Explanation of the Judgment
Key Issues and Analysis
A. Circumstantial Evidence and Legal Standards
The Supreme Court emphasized that in cases based on circumstantial evidence, the chain of events must be complete, consistent, and conclusive to rule out any hypothesis of innocence. The prosecution failed to meet this standard due to:
Unreliable Witnesses: The star witness (PW-5) delayed reporting the crime for six days without justification. His testimony was deemed unnatural and untrustworthy.
Gaps in Evidence: No forensic link was established between the recovered sickle (alleged murder weapon) and the victims’ injuries.
B. Last-Seen Theory
The prosecution relied on the "last-seen" theory (accused seen with victims before their deaths). However, the Court noted:
Weak Corroboration: PW-5’s conduct (not informing authorities promptly) cast doubt on his credibility.
No Direct Link: The accused’s possession of a sickle was explained by his occupation (coconut cutter), weakening the prosecution’s claim.
C. DNA Evidence and Procedural Lapses
The DNA evidence was discarded due to:
Chain of Custody Issues: Vaginal swabs were delayed (41 days) in reaching the lab, risking contamination.
Unrecorded Handling: No documentation of storage/transfer of samples, violating forensic protocols.
Contradictions in Testimony: Doctors and investigators gave conflicting accounts of sample custody.
D. Confession and Recovery
The accused’s confession and recovery of stolen jewelry were deemed inadmissible because:
Coercion Concerns: No independent witnesses attested to the voluntariness of the confession.
Unverified Recovery: The gold chain’s ownership was not conclusively proven, and other stolen items (e.g., mobile phone) were never recovered.
E. Faulty Investigation
The Court criticized the investigation for:
Non-Examination of Key Witness: Bhagyalakshmi (a critical eyewitness) was never examined.
T.I. Parade Flaws: The identification parade was conducted after undue delay, and the witness had prior exposure to the accused.
Lack of Motive: No evidence showed the accused disposed of other valuables (e.g., victim’s ring), undermining the robbery motive.
Final Decision
The Supreme Court:
Acquitted the appellant due to insufficient evidence and procedural irregularities.
Directed Immediate Release unless required in another case.
Issued Guidelines for DNA evidence handling to prevent future lapses.
Significance
The judgment underscores:
The necessity of meticulous investigation in capital cases.
The dangers of relying on circumstantial evidence without a foolproof chain.
The right to a fair trial under Article 21 of the Constitution.
Note: The Court also hinted at potential compensation for wrongful incarceration, urging legislative action.