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 of India |
| Overrules / Affirms |
|
| Type of Law | Criminal Law |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that conviction under the SC/ST Act requires proof that the accused knew the victim’s caste status and that the offence was committed on that ground. A confession obtained in police custody cannot be relied upon and recoveries claimed under Section 27 Evidence Act must arise from truly concealed objects, not routine searches. “Last seen together” without prior acquaintance does not supply proof of guilt. IPC convictions for rape and murder were sustained based on medical evidence, DNA profiling and unbroken chain of circumstances. Sentencing principles allow modification of life imprisonment to a fixed term when the offence does not fall in the “rarest of rare” category. |
| Logic / Jurisprudence / Authorities Relied Upon |
|
| Facts as Summarised by the Court | A woman hawker went missing and was found raped and murdered. Three accused were seen near the scene and later held by police. Medical evidence showed ante-mortem injuries and semen matching two accused. No prior acquaintance or knowledge of caste was proved. Confession made in custody and recoveries under Section 27 were found inadmissible. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in India |
| Persuasive For | High Courts and trial courts on admissibility of confessions and Section 27 recoveries |
| Overrules | Division Bench’s conviction under Sections 3(1)(w)(i) & 3(2)(v) of the SC/ST Act |
| Distinguishes | Application of “last seen together” theory where no prior acquaintance between accused and victim is proved |
| Follows | Established principles on Section 27 recoveries and confessions in custody |
What’s New / What Lawyers Should Note
- Clarifies that Sections 3(1)(w)(i) and 3(2)(v) of the SC/ST Act demand proof that the accused knew the victim’s caste status.
- Confessions made in police custody to witnesses brought by the police are inadmissible.
- Recoveries under Section 27 Evidence Act must stem from disclosures of concealed objects—not routine searches post-arrest.
- “Last seen together” is not a standalone circumstance unless prior acquaintance is proved.
- Life sentence in non–rarest-of-rare cases may be limited to a fixed term (e.g., 25 years).
Summary of Legal Reasoning
- Absence of proof that the accused knew the victim’s caste status defeats convictions under the SC/ST Act (Sections 3(1)(w)(i) & 3(2)(v)).
- Confession to PW15 in police custody cannot be relied upon; it violates safeguards against coerced statements.
- Recoveries of mobile, knife and cash at the time of arrest were not “concealed” disclosures under Section 27 Evidence Act and thus inadmissible.
- IPC convictions (Sections 302, 376D read with 34 IPC) upheld on unbroken chain of circumstances: medical evidence, DNA profiling, time-of-death alignment and failure of accused to establish alibi.
- Sentencing under Section 302 IPC in non–rarest-of-rare category adjusted from life-until-death to life-for-25-years, applying mitigating factors (age, family responsibilities, no past record).
Arguments by the Parties
Petitioner (A2):
- No proof he knew the victim’s caste; SC/ST Act convictions unsustainable.
- Confession in police custody and recoveries under Section 27 are inadmissible.
- Life-until-death sentence is disproportionate; case not in “rarest of rare.”
Respondent (State of Telangana):
- Victim’s caste was established; knowledge should be presumed.
- Confession and recoveries were valid; police procedure complied.
- Seriousness of rape and murder warrants life-until-death sentence.
Factual Background
On 24 November 2019, a hawker’s wife was dropped at Yellapatar Village and reported missing. Her body, showing ante-mortem injuries, was found next day in bushes near Ramnaik Thanda. A1–A3 were seen in the vicinity shortly before the crime. FIR charged them with rape (Section 376D IPC), murder (Section 302 IPC), theft (Section 404 IPC) and offences under the SC/ST Act. Medical and DNA evidence linked two accused to the rape; no proof of caste knowledge or proper Section 27 recoveries was found.
Statutory Analysis
- Sections 3(1)(w)(i) & 3(2)(v), SC/ST (PoA) Act, 1989: Knowledge of victim’s caste is essential.
- Section 27, Evidence Act, 1872: Admissible only for recovery of objects truly concealed as per disclosure.
- Section 106, Evidence Act, 1872: No presumption of guilt from “last seen together” without additional link.
- Sections 302 & 376D read with Section 34 IPC: Conviction based on DNA, medical and circumstantial evidence.
- Section 404 read with Section 34 IPC: Acquittal where ownership of stolen mobile and SIM card unproven.
Alert Indicators
- 🚨 Breaking Precedent – Quashes SC/ST Act convictions without proof of caste-knowledge
- ✔ Precedent Followed – Principles on confession admissibility and Section 27 recoveries
- 🔄 Conflicting Decisions – Overrules High Court’s application of SC/ST Act provisions