Legal Review and Analysis of Nagamma @ Nagarathna & Ors vs State of Karnataka 2025 INSC 1135

1. Heading of the Judgment

Case Title: Nagamma @ Nagarathna & Ors. vs. State of Karnataka
Citation: Criminal Appeal No. 425 of 2014, 2025 INSC 1135
Court: Supreme Court of India
Bench: Justice K. Vinod Chandran and Justice K. V. Viswanathan
Date of Judgment: September 22, 2025

2. Related Laws and Sections

This judgment extensively discusses and applies the following legal provisions:

• Indian Penal Code, 1860 (IPC):
  Section 302: Punishment for Murder.
  Section 34: Acts done by several persons in furtherance of common intention.
  Section 109: Punishment for abetment if the act abetted is committed in consequence.

• Indian Evidence Act, 1872:
  Section 25: Confession to police officer not to be proved.
  Section 26: Confession by accused while in custody of police not to be proved against him.
  Section 27: How much of information received from accused may be proved.
  Section 106: Burden of proving fact especially within knowledge.
  Section 161: Examination of witnesses by police.

3. Basic Judgment Details

This criminal appeal was filed by the appellants (A2, A3, and A4) challenging their conviction and life sentence upheld by the High Court of Karnataka. They were convicted for the murder of a police constable (the deceased) under Section 302 read with Section 34 of the IPC. The prosecution's case was based entirely on circumstantial evidence, as there were no direct eyewitnesses. The Supreme Court was tasked with evaluating whether the chain of circumstantial evidence was complete and conclusive enough to sustain the conviction.

4. Core Principle and In-Depth Analysis of the Judgment

The core principle reaffirmed by this judgment is the stringent standard of proof required in cases based solely on circumstantial evidence. The Court emphasized that for a conviction to stand, the circumstances must form a complete, unbreakable chain that points unequivocally to the guilt of the accused and is inconsistent with any other reasonable hypothesis of innocence.

The Central Issue

The central issue was whether the prosecution successfully proved its case beyond a reasonable doubt by establishing a cogent and complete chain of circumstantial evidence linking the appellants to the murder.

Analysis of the Supreme Court's Scrutiny

The Court meticulously dismantled the prosecution's case by analyzing each circumstantial link:

A. Failure to Prove Motive
The prosecution alleged that the murder was motivated by the deceased's persistent demands for repayment of a loan of Rs. 1 lakh given to A1 (who was acquitted by the trial court). The Supreme Court found the evidence on motive to be weak and unreliable. Key witnesses, including the wife of the deceased (PW-18) and a colleague (PW-7), either did not support the motive theory in their chief examinations or were declared hostile. The Court held that while the absence of motive is not fatal when other evidence is strong, its failure in this case was a significant factor weighing in favour of the accused. [Refer to Paragraphs 10-14 of the Judgment]

B. Unreliable Evidence of Dead Body at the Accused's House
A critical circumstance relied upon by the lower courts was the discovery of the deceased's body at the house of A1 and A2. The Supreme Court found major contradictions in the testimonies of witnesses (PW-18, PW-6, PW-8, PW-16) regarding where they first saw the body—some stated it was at the accused's house, while others, including the deceased's wife, stated it was at the hospital. The Court cited Santosh v. State (NCT of Delhi) (2023) and Shivaji Chintappa Patil v. State of Maharashtra (2021) to reiterate that merely finding a dead body on a person's property does not lead to a presumption of guilt. The prosecution must first establish a prima facie case before invoking Section 106 of the Evidence Act (burden to explain facts within special knowledge). [Refer to Paragraphs 15-22 of the Judgment]

C. Inadmissible Extra-Judicial Confessions
The prosecution claimed that A2 confessed the crime to several individuals, including the Station House Officer (PW-15) and the wife of the deceased (PW-18). The Supreme Court categorically rejected these confessions. Applying Sections 25 and 26 of the Evidence Act, the Court held that:

• Confessions made to a police officer (PW-15) are completely inadmissible.

• Confessions made while in the custody of the police, even if made to a civilian (like PW-18) inside the police station, are inadmissible unless made in the immediate presence of a Magistrate.
  The Court found that all alleged confessions occurred within the police station environment and were therefore untrustworthy and legally invalid. *[Refer to Paragraphs 23-25 of the Judgment]*

D. Flawed Recovery of Weapon (Chopper)
The recovery of a murder weapon (a chopper) at the instance of A4 under Section 27 of the Evidence Act was another key circumstance. The Court identified several flaws:

• The Investigating Officer (PW-24) stated that both A3 and A4 made disclosure statements, but it was unclear if they were simultaneous or sequential, creating doubt about the originality of the information.

• The witnesses to the recovery (PW-2 and PW-3) turned hostile, stating they signed the recovery documents at the police station, not the actual spot.

• Crucially, there was no forensic evidence (like blood stains or fingerprints) to link the recovered chopper to the crime.
  The Court, relying on Manoj Kumar Soni v. State of M.P. (2023), held that a disclosure statement, by itself, is not sufficient to prove guilt beyond a reasonable doubt without corroborative evidence. [Refer to Paragraphs 26-31 of the Judgment]

E. Hostile Witnesses and Lack of Genesis of Crime
The Court noted that the purported eyewitnesses (PW-20 and PW-22) completely turned hostile and provided no evidence supporting the prosecution. Furthermore, the timeline of events was unclear—the prosecution could not establish what transpired between the deceased's alleged arrival at the accused's house and the time of death. This created a "suspicion as to the genesis and origin of the crime," compounding reasonable doubt. [Refer to Paragraphs 32-34 of the Judgment]

5. Final Outcome of the Judgment

The Supreme Court allowed the appeal. It held that the prosecution failed to establish a complete and unbreakable chain of circumstantial evidence. The conviction and life sentence imposed on Appellants A2, A3, and A4 by the Trial Court and upheld by the High Court were set aside. The appellants were acquitted of all charges. The Court directed their immediate release if they were in custody, provided they were not wanted in any other case.

6. MCQs Based on the Judgment

Question 1 In Nagamma @ Nagarathna & Ors. vs. State of Karnataka (2025 INSC 1135), the Supreme Court declared the extra-judicial confession made by accused A2 to the wife of the deceased (PW-18) as inadmissible. What was the primary legal reason for this decision?

(a) The confession was not recorded in writing.
(b) The confession was not made voluntarily.
(c) The confession was made while the accused was in the police station, which constitutes police custody.
(d) The witness (PW-18) was declared hostile by the prosecution.

Question 2 The Supreme Court acquitted the appellants primarily because the case was based on circumstantial evidence and the prosecution failed to meet a crucial legal standard. What is that standard?
(a) The evidence must prove motive beyond any doubt.
(b) The circumstances must form a complete chain pointing only to the guilt of the accused, excluding any reasonable hypothesis of innocence.
(c) There must be at least one reliable eyewitness to the crime.
(d) The recovery of the murder weapon must be supported by forensic evidence.