K.P. Tamilmaran v. State by Deputy Superintendent of Police & Connected Appeals (2025)

Case Summary: K.P. Tamilmaran v. State by Deputy Superintendent of Police (2025)

1. Case Title & Citation

Full name of the case: K.P. Tamilmaran v. State by Deputy Superintendent of Police & Connected Appeals (2025)

Official citation: [2025] INSC 576

2. Court Name & Bench

Court: Supreme Court of India

Bench: Division Bench, Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra

3. Date of Judgment

28 April 2025

4. Parties Involved

Petitioners/Appellants:

K.P. Tamilmaran (Sub-Inspector, accused A-14) and ten co-accused, including Inspector M. Sellamuthu (A-15) and other members of the Vanniyar community, convicted of offences under IPC and the SC/ST Act.

Respondent/Defendant:

State of Tamil Nadu by Deputy Superintendent of Police

5. Facts of the Case

The case dates to 2003 when an inter-caste couple was brutally killed in Tamil Nadu following a caste-based honour killing. Chemical engineering graduate Murugesan, belonging to the Dalit community, and Vanniyar caste woman Kannagi, planned to marry on 5 May 2003 against the social expectations as predicted. Kannagi’s family were against their union and wanted to protect their caste ‘honour’. Kannagi’s family kidnapped and killed the couple gruesomely and then staged a scene to implicate them in to cover the crime with the help of some local police officials.

On 07 July 2003, Murugesan was lured back to his village Pudukoorapettai by Kannagi’s father (A-1) and brother Maruthupandiyan (A-2) on the pretext that stating that he owed him (A-2) money. As soon as Murugesan came there, (A-1 to A-13) tortured him publicly till he disclosed the whereabouts of Kannagi.

They took the couple to a nearby cashew grove, where A-2 made Kannagi drink Nuvacron (Monocrotophos insecticide) and she died on the spot. Murugesan was poisoned similarly and died shortly after. Their corpses were cremated privately.

The crime, which took place in a rural town in Tamil Nadu, went unnoticed for several days because Sub-Inspector Tamilmaran (A-14) and Inspector Sellamuthu (A-15) did not register an FIR and played an active and direct role in suppressing the case. The Central Bureau of Investigation (CBI) subsequently took over the case as they latter registered an FIR following public outcry and media pressure from human rights activists who wanted the full extent of the crime exposed. The initial investigation falsely implicated Dalits witnesses and fabricated confessions.

This led to the eventual arrest of 15 individuals, including the relatives of the Kannagi and police officers who had been complicit in covering up the crime. Among the accused, 13 were convicted by the trial court, and the judgement was appealed against before the Madras High Court, which commuted A-2’s life sentence to life and A-14’s sentence to two years. A-3 and A-13 were acquitted. While modifying some sentences, the Madras High Court also upheld the life term for the main accused, and the case was then moved to the Supreme Court.

6. Issues Raised

• Whether the conviction for ‘murder’ charge under Section 302 of Indian Penal Code (IPC) is valid, given the nature of the crime being an “honour killing”
• Whether, evidence from hostile and associate witnesses were admissible and credible that led to conviction.
• Whether summoning PW-49 (stepmother) mid-trial was legally valid under Section 311 CrPC.
• Whether police officers were liable for further criminal action for failing to register FIR and for their complicity in the cover-up constituted offences under IPC ss 217–218, SC/ST Act ss 3(2)(i), 4:
• Whether delays in procedure compromised the fairness of trial and the credibility of witnesses.

7. Arguments of the Parties

Petitioners/Appellants argued:

• Challenged that the Trial as well as the High Court had erred by relying on evidence of hostile witnesses without corroboration, breaching the principles of Khijiruddin Sonar v Emperor & Praphullakumar Sarkar v Emperor[1].
• Argued that summoning PW-49 under CrPC s 311 was illegal after charge-sheet closure and was against fair trial rules.
• Claimed that lack of evidence liked to the direct involvement of A-14 or A-15 in murders ; police inaction does not count as intentional dereliction under IPC ss217-218.

Respondent/State contended:

• Stressed up the severity of the crime, calling it an “honour killing” based on caste-related hostility.
• Argued that there was adequate evidence, including forensic evidence and eyewitness testimonies to convict the accused of murder.
• Since the unshaken parts of the hostile and related witnesses (PW-1, PW-2, PW-3, PW-15, PW-49) were speaking to the conscious possession of the seized articles and were sufficient to prove the guilt beyond any reasonable doubt; partial reliance was permissible and legally admissible as per Praphullakumar Sarkar[2].
• Argued that the Trial courts have wide discretion under s 311 CrPC and under Section 165 of the Evidence Act to call for material witnesses[3].
• Stressed that police delaying or hiding a FIR was a violation of their duties, as per Lalita Kumari v State of Uttar Pradesh[4], making them more liable under SC/ST Act.

8. Judgment / Final Decision

The Supreme Court turned down all appeals and upheld the High Court’s decisions. The key outcomes or decisions:

• A-14’s conviction under IPC s 217 and SC/ST Act s 4 was upheld, and the two-year sentence was confirmed.
  • A-15’s convictions under IPC ss 217–218 and SC/ST Act ss 3(2)(i), 4 were upheld, and he will spend the rest of his life in prison.
  • A-2’s life sentence was upheld.
  • No interference with the acquittals of A-3 and A-13.
  • The State of Tamil Nadu was told to pay ₹500,000 in compensation to both PW-1 (Murugesan’s father) and PW-49 (stepmother), on top of what the trial court had already given them.

9. Legal Reasoning / Ratio Decidendi

The Supreme Court underscored that witnesses considered hostile are not inherently unreliable. As per Praphullakumar Sarkar v Emperor[5] and Jaikam Khan v State of U.P.11[6], courts can rely on believable portions if corroborated. Related witnesses like kin are “natural witnesses” and their testimony ought to be evaluated carefully, not dismissed altogether as per State of A.P. v S Rayappa[7]. 

Section 311 CrPC empowers judges to summon or recall witnesses at any phase if fundamental to fairness. This discretion is supplemented by Section 165 of the Evidence Act, allowing the judiciary to pose any inquiries to uncover truth.13 Including PW-49, even belatedly, was deemed lawful and critical to justice.

The Court maintained that A-14 and A-15’s failure to register the FIR and fabrication of proof broke Sections 154–157 CrPC and attracted aggravated offenses under IPC s 218 and SC/ST Act s 3(2)(i)[8]. A-15’s role in falsely implicating Dalit witnesses was especially egregious. 

Fabricating proof and framing of Dalit relatives attracted aggravated offenses under IPC s 218 and SC/ST Act s 3(2)(i), warranting life imprisonment.  Under Article 21 and victim-compensation jurisprudence, the Court awarded additional payment to the victims’ families, acknowledging the mental and social misery inflicted by caste-based violence.

10. Conclusion / Observations

The Court underscored the importance of eradicating caste-based violence, particularly in cases of honor killing, as they violate basic rights guaranteed by the Constitution, such as the right to life and personal liberty (Article 21). The court emphasized that police officials must not only be vigilant in preventing such crimes but also be held accountable for any actions or inactions that may lead to the concealment of crimes. The Court cited the State of Rajasthan v. Kashi Ram (2006)[9], where failure by the police to act was treated as an aggravating factor.

The judgment also referred to the principles established in Lata Singh v. State of Uttar Pradesh (2006),[10] where the Supreme Court had previously dealt with the issue of honour killings, affirming that the right to choose one’s life partner transcends the rights of any third party or caste. The Court took a firm stance against the delay in the delivery of justice, highlighting that such cases erode public trust in the legal system. The Court opined that timely justice delivery is essential, especially in cases involving marginalized communities.

The Supreme Court affirmed convictions for caste-based violence, strengthening women’s legal protections. The decision emphasised how hard it is to get rid of discrimination based on caste and how important it is to make changes. The court called for policies that would include all citizens and respect their freedom and human dignity, no matter their gender or social position. This ruling is a reminder of the ongoing fight for equality and equal treatment under the law. It also makes it clear that reforms and changes need to happen in society.

Reference(S):

[1] Khijiruddin Sonar v Emperor (1925) Cal 78; Praphullakumar Sarkar v Emperor (1931) Cal 8.

[2] Praphullakumar Sarkar v Emperor (1931) Cal 8 (n 7) refined hostile-witness doctrine.

[3] Code of Criminal Procedure 1973, s 311; Evidence Act 1872, s 165

[4] Lalita Kumari v State of Uttar Pradesh [2014] 2 SCC 1

[5] Praphullakumar Sarkar v Emperor (1931) Cal 8.

[6] Jaikam Khan v State of U.P. [2021] 13 SCC 716

[7] State of A.P. v S Rayappa [2006] 4 SCC 512.

[8] Indian Penal Code 1860, ss 217–218; Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act 1989, ss 3(2)(i), 4

[9] State of Rajasthan v. Kashi Ram [2006] 12 SCC 56

[10] Lata Singh v. State of Uttar Pradesh [2006] 5 SCC 47