Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | Crl.A. No.-005534-005534 – 2025 |
| Diary Number | 12564/2024 |
| Judge Name | HON’BLE MR. JUSTICE AHSANUDDIN AMANULLAH |
| Bench |
HON’BLE MR. JUSTICE AHSANUDDIN AMANULLAH HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Precedent Value | Binding on all courts |
| Overrules / Affirms |
|
| Type of Law | Criminal law |
| Questions of Law |
|
| Ratio Decidendi |
The SC/ST (Prevention of Atrocities) Act requires the prosecution to prove that the accused were aware of the victim’s SC/ST status; absent such knowledge, essential ingredients of Sections 3(1)(w)(i) and 3(2)(v) are not made out. Confessions elicited while in police custody cannot be relied upon, and recoveries alleged under Section 27 must arise from disclosure of concealed material to independent witnesses. The conviction under IPC Sections 302 and 376D read with Section 34 was upheld on the basis of medical evidence, circumstantial links and DNA matches. The life sentence “till last breath” under Section 302 IPC is not mandatory in every case and may be reduced based on mitigating factors such as age, family responsibilities and absence of prior criminality. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court | On 24.11.2019 the deceased was dropped at Yellapatar Village and found missing the next day; her body was recovered in nearby bushes and an FIR was lodged under IPC Sections 302, 376D read with Section 34 and SC/ST Act Sections 3(2)(v) and 3(1)(w)(i). Three accused were convicted at trial; the High Court confirmed convictions and life sentence till last breath for one accused (A2). |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and High Courts when interpreting SC/ST Act ingredients and Section 27 Evidence Act |
| Persuasive For | Future benches considering confession admissibility and sentencing modulations under “rarest of rare” doctrine |
| Overrules | Convictions under Sections 3(1)(w)(i) & 3(2)(v) of the SC/ST Act absent proof of accused’s knowledge of victim’s caste |
What’s New / What Lawyers Should Note
- The SC/ST Act mandates proof that the accused knew the victim’s caste status; mere proof of victim’s caste is insufficient.
- Confessions made in police custody and recoveries labelled under Section 27, Evidence Act, without genuine concealment and independent witness seizure, are inadmissible.
- Section 27 recoveries must strictly follow disclosure-to-witnesses principle; arrests and routine search do not qualify.
- Life imprisonment “till last breath” can be reduced to a term (e.g., 25 years) if mitigating factors like age, family dependents and clean antecedents are established.
Summary of Legal Reasoning
- Examined the High Court’s reliance on “last seen together” and Section 106 Evidence Act — held insufficient linkage without acquaintance.
- Held confessions made in police custody inadmissible; police-elicited statements cannot ground conviction.
- Disallowed recoveries under Section 27 when material was not genuinely concealed and not seized from location disclosed to independent witnesses.
- Upheld IPC Sections 302 & 376D read with Section 34 convictions on the basis of circumstantial evidence, medical injuries, time of death, and DNA match.
- Quashed SC/ST Act convictions (Sections 3(1)(w)(i) & 3(2)(v)) for failure to prove accused had knowledge of victim’s caste status.
- Modified A2’s sentence under Section 302 IPC from life till last breath to life for 25 years without remission, applying “rarest of rare” sentencing principles.
Arguments by the Parties
Petitioner (A2):
- Challenged quantum of sentence under Section 302 IPC as excessive.
- Contended SC/ST Act convictions unsustainable absent proof of knowledge of caste.
- Argued confessions and Section 27 recoveries were inadmissible.
- Emphasized mitigating factors: age, family responsibilities, first offence, no danger to society.
Respondent (State of Telangana):
- Supported upholding conviction and life sentence, but did not contest modification of life term.
- Maintained that prosecution had proved all IPC ingredients for rape and murder.
Factual Background
On 24 November 2019, the victim was dropped at Yellapatar Village and went missing; her body was found next day in nearby bushes. FIR was registered for rape (Section 376D IPC), murder (Section 302 IPC) and offences under the SC/ST Act. Three accused were tried and convicted at the trial court; the High Court confirmed convictions and imposed life imprisonment till last breath for one appellant (A2). A2 appealed only against the sentence and SC/ST Act convictions.
Statutory Analysis
- SC/ST (Prevention of Atrocities) Act, 1989 Section 3(1)(w)(i) & 3(2)(v): conviction requires knowledge of victim’s scheduled caste status; this ingredient was held missing.
- Indian Evidence Act, 1872 Section 27: recovery admissibility demands that accused disclose the concealment location to independent witnesses and that seizure occurs at that location.
- IPC Section 302 & 376D read with Section 34: upheld on circumstantial and forensic evidence.
- Sentencing under IPC Section 302: “rarest of rare” doctrine applied to reduce life till death to 25 years without remission.
Dissenting / Concurring Opinion Summary
No separate dissenting or concurring opinions were recorded; the judgment was unanimous.
Procedural Innovations
None noted beyond reaffirmation of established principles on confession admissibility and SC/ST Act ingredients.
Alert Indicators
- 🚨 Breaking Precedent – Convictions under SC/ST Act cannot stand without proof of accused’s knowledge of victim’s caste status.
- ✔ Precedent Followed – Strict application of Section 27, Evidence Act, on admissibility of recoveries from disclosures.