Conviction for murder upheld where credible eyewitness testimony was corroborated by medical and circumstantial evidence.

The deceased, Gunavel, was married to P.W.3, the appellant’s daughter, and resided with her as a tenant in premises let out by P.W.1.

On 10 June 2018, following a quarrel in which the deceased allegedly assaulted P.W.3, she informed her mother, and the appellant went to the deceased’s residence.

P.W.1 testified that the appellant abused and threatened the deceased before stabbing him repeatedly on the chest and neck with a knife; the appellant then fled on a motorcycle.

P.W.5, another resident of the police quarters, arrived on hearing the commotion and saw the deceased lying in a pool of blood while the appellant was leaving the scene.

The deceased died from shock and haemorrhage caused by multiple stab injuries, as confirmed by the post-mortem evidence.

The appellant was arrested after surrendering before a Magistrate, and the police recovered the alleged knife, clothing and motorcycle pursuant to his confession.

The Sessions Court convicted him under Section 302 IPC and sentenced him to life imprisonment with a fine of ₹1,000; he challenged the conviction under Section 374(2) Cr.P.C.

Whether the testimony of P.W.1, as the principal eyewitness, was sufficiently reliable to sustain the appellant’s conviction for murder under Section 302 IPC in the absence of CCTV footage and further eyewitness corroboration?

Whether the evidence of P.W.5, P.W.3’s testimony regarding the preceding quarrel and the appellant’s subsequent conduct, together with the medical evidence, corroborated the prosecution case beyond reasonable doubt?

Whether the trial court’s conviction and sentence required interference in appeal under Section 374(2) Cr.P.C.?

The Court applied Section 302 of the Indian Penal Code, which criminalises murder and prescribes the applicable punishment.

It assessed the prosecution evidence according to the principle that a conviction may be based on reliable and cogent eyewitness testimony, even where the prosecution primarily relies on one eyewitness, provided the testimony is consistent and is supported by surrounding circumstances and medical evidence.

The Court also applied Section 6 of the Indian Evidence Act, 1872, treating P.W.5’s immediate observation of the appellant leaving the scene and the deceased lying injured as part of the same transaction and as relevant corroborative evidence.

The appellant’s conduct—remaining away from home after the occurrence and failing to respond when questioned by his daughter—was considered as a circumstance pointing towards guilt.

The appellate court’s function under Section 374(2) Cr.P.C. was to examine whether the conviction and sentence warranted appellate interference.

The Court found P.W.1’s evidence natural, consistent and trustworthy.

His presence at the premises was established because he was the landlord and a resident of the same campus, and there was no demonstrated motive for him to falsely implicate the appellant.

P.W.1 gave a direct account of the appellant’s threats and repeated stabbing of the deceased, which corresponded with the injuries recorded in the post-mortem certificate.

P.W.5’s contemporaneous observation of the appellant leaving the place while the deceased lay in a pool of blood corroborated P.W.1’s account and was treated as relevant under Section 6 of the Evidence Act.

P.W.3’s evidence established the immediate motive arising from the deceased’s assault on her, while the appellant’s failure to return home and his silence when questioned were treated as additional incriminating circumstances.

The absence of CCTV footage and the alleged lack of detailed injury particulars in the complaint did not create reasonable doubt because the direct eyewitness account was supported by independent circumstantial and medical evidence.

It found the evidence of P.W.1 reliable and sufficiently corroborated by P.W.5, P.W.3, the medical evidence and the appellant’s conduct.

The criminal appeal was dismissed, and the judgment dated 29 January 2020 in S.C. No. 137 of 2019, convicting the appellant and sentencing him to life imprisonment with a fine of ₹1,000, was confirmed.

The Sessions Court was directed to secure the appellant if he was on bail so that he could undergo the remaining sentence.