Summary and Analysis of Esakkimuthu & Anr. vs. State represented by Inspector of Police

1. Heading of the Judgment

Esakkimuthu & Anr. vs. State represented by Inspector of Police
(Criminal Appeal Nos. arising from SLP (Crl) 1693 & 3816 of 2025)
Date: July 22, 2025
Bench: Vikram Nath & Sandeep Mehta, JJ.
Outcome: Acquittal of the accused-appellants.

2. Relevant Laws & Sections

• Indian Penal Code (IPC), 1860:
  Section 302: Punishment for murder.
  Section 34: Acts done by several persons in furtherance of common intention.
  Section 120B: Criminal conspiracy (charges not proven).

• Tamil Nadu Goondas Act, 1982:
  Deceased was a detained history-sheeter under this law.

3. Basic Judgment Details

AspectDetailsPartiesAppellants: Esakkimuthu (A2)  Accused No. 2  & Pitchu Mani @ Pitchai Mani (A1).
Respondent: State of Tamil Nadu.Lower CourtsTrial Court (04.03.2020): Convicted A1 u/s 302 IPC, A2 u/s 302/34 IPC. Sentenced to life imprisonment.
High Court (10.09.2024): Upheld conviction.Key AllegationsA2 lured the deceased to a liquor shop. A1 attacked him with an aruval (sickle) to avenge past enmity.Prosecution EvidenceEyewitnesses: (PW-1)  Prosecution Witness-1(son) & PW-2 (wife of deceased).
Other witnesses: Hostile (PW-4 to PW-6).
Medical report: 26 injuries on the deceased.Supreme Court RulingAcquitted both accused due to unreliable eyewitness accounts and unproven prosecution case.

4. Explanation of the Judgment

Background of the Case

• The deceased (Edison Suvisedha Muthu) had past enmity with Balasubramanian (A1’s father), whom he had attacked earlier.

• On April 14, 2013, A2 took the deceased to a liquor shop (TASMAC) on his motorcycle.

• PW-1 (son) and PW-2 (wife) claimed they followed on a bicycle, witnessed A1 murder the deceased at the shop, and returned home without reporting to police en route.

Prosecution’s Case

• Relied heavily on testimonies of PW-1 & PW-2.

• Cited motive (past enmity) and recovery of the murder weapon (aruval) and motorcycle.

• Medical evidence showed 26 injuries on the deceased.

Defense’s Key Arguments

1. Improbable Eyewitness Presence:
   Distance between home and crime spot: 16 km.
   PW-1 & PW-2 allegedly covered this on a bicycle in 30 minutes (deceased left at 12:00 PM; murder at 12:30 PM).
   Supreme Court held this was physically impossible, even for a 17-year-old (PW-1) cycling with his mother (PW-2).

2. Unnatural Conduct of Witnesses:
   No attempt to intervene during the attack.
   Did not report the crime at a police station on their way back.

3. Hostile Independent Witnesses:
   Shop customers (PW-4, PW-5) and manager (PW-6) turned hostile. They stated 4–5 attackers were involved (contradicting prosecution’s 2-accused theory).

4. Medical Evidence:
   26 injuries suggested attack by multiple persons, not a single assailant (A1).

Supreme Court’s Reasoning

• Eyewitness Testimony Unreliable:
  PW-1 & PW-2 were "interested witnesses" (deceased’s family). Their evidence required strict scrutiny.
  Their presence at the crime spot was doubtful due to the improbable 16 km/30-minute bicycle ride.

• Other Loopholes:
  No explanation for not reporting the crime immediately.
  Hostile witnesses and medical evidence suggested alternate theories (attack by unknown group).

• Benefit of Doubt:
  Prosecution failed to prove guilt beyond reasonable doubt. Accused entitled to acquittal.

Final Decision

• Convictions overturned.

• Appellants (A1 & A2) acquitted and ordered to be released immediately.

Key Takeaway: The Supreme Court emphasized that improbable eyewitness accounts, absence of independent corroboration, and unexplained gaps in the prosecution’s story create reasonable doubt, warranting acquittal.