Madras High Court

Entries in an accident register cannot be used to discredit otherwise unassailable eyewitness testimony.

Muthukumar vs The Inspector of Police

Madras High CourtJUDGMENT: March 25, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant/accused was married to the deceased, Pon Irul. Due to the accused’s suspicions regarding her chastity, the deceased resided with her parents

Source reference: p. 2

On 24.11.2017, while the deceased was walking to a hospital with her parents (PW1 and PW2), the accused allegedly intercepted her, pulled her hair, and slit her throat with a knife (MO1) in an open field

Source reference: p. 3

The deceased was taken to the hospital but succumbed to injuries en route.

Source reference: p. 3

The Trial Court convicted the accused under Sections 342 and 302 of the IPC

Source reference: p. 2

On appeal, the accused challenged the conviction primarily on a discrepancy: while PW1 and PW2 claimed the incident occurred in an open field, the Accident Register (Ex.P9) recorded the deceased stating the attack happened while she was "working in her house"

Source reference: p. 8, 21
02

Issues

1. Whether the discrepancy between the eyewitness accounts (location: open field) and the entry in the Accident Register (location: house) is sufficient to discredit the prosecution's case

Source reference: p. 11

2. Whether the entries made by a medical professional in an Accident Register (AR) carry the status of an absolute statement or "gospel truth" that can override credible ocular evidence

Source reference: p. 18, 25
03

Law Applied

The Court applied Sections 302 (Murder) and 342 (Wrongful Confinement) of the IPC, and Section 32 (Dying Declaration) and Section 6 (Res Gestae) of the Indian Evidence Act

Source reference: p. 9, 20

It relied on the precedent in Pattipati Venkaiah v. State of Andhra Pradesh, which established that a doctor’s primary duty is to save lives, not to record the details of the crime or identify assailants

Source reference: p. 12

per P. Babu v. State of A.P. and Saranraj v. State, the court held that AR entries are intended for medical treatment purposes and need not possess scientific or investigative precision

Source reference: p. 13, 18

The court also invoked the "conscientious judicial mind" standard for "reasonable doubt" from State of Haryana v. Bhagirath

Source reference: p. 22
04

Reasoning

The Court observed that the testimony of PW1 and PW2 was consistent, corroborated by their Section 164 Cr.P.C. statements, and inspired confidence despite their relationship to the deceased

Source reference: p. 19-20

Regarding the discrepancy in the Accident Register (Ex.P9), the Court reasoned that a doctor (PW8) focuses on emergency treatment rather than investigative details

Source reference: p. 24

The Court emphasized that AR entries are merely a relevant piece of evidence to understand medical history and cannot be elevated to a status that discredits unassailable eyewitness accounts

Source reference: p. 18

It held that "reasonable doubt" is not a technical tool to be applied to every segment of evidence but must be a doubt that a conscientious mind entertains after considering the entire evidence

Source reference: p. 23

Since the medical evidence (postmortem) corroborated the nature of injuries described by the eyewitnesses, the minor discrepancy regarding the exact location mentioned in the AR was deemed irrelevant

Source reference: p. 25
05

Holding

The Court held that the prosecution proved the case beyond reasonable doubt, and the entries in the Accident Register did not take away the merits of the ocular testimony

The Court dismissed the criminal appeal and confirmed the judgment of the Fast Track Mahalir Court, Ramanathapuram, upholding the conviction and sentence of life imprisonment under Section 302 IPC and six months simple imprisonment under Section 342 IPC

Source reference: p. 2, 26
Madras High Court

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MuthukumarvsThe Inspector of Police

Madras High Court · March 25, 2026

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