Honour Killing Is the Most Dishonourable Act in the Name of Honour: Supreme Court Upholds Life Sentences for Brutal Inter-Caste Murders

“Hostile Witness Evidence Cannot Be Wiped Out from Record”, - Supreme Court of India, comprising Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra, delivered a strong judgment in the case of K.P. Tamilmaran vs. The State by Deputy Superintendent of Police, arising from the gruesome honour killing of an inter-caste couple, Murugesan and Kannagi, in Tamil Nadu. The Court upheld the convictions and sentences of eleven accused, including two police officers, for their roles in the murder and subsequent cover-up. It emphasized the grave abuse of caste-based violence and the legal duty to counter systemic police misconduct, while setting important principles on the evidentiary value of hostile witnesses and the proactive role courts must play in the criminal justice system.

The tragedy stemmed from the secret marriage of Murugesan, a Dalit, and Kannagi, a member of the dominant Vanniyar community. When the marriage came to light, the couple was abducted by Kannagi’s family and brutally murdered by being forcibly administered poison in full public view.
Shockingly, the local police, including officers A-14 and A-15, colluded with the perpetrators by suppressing the crime, refusing to register an FIR, and fabricating evidence to falsely implicate members of the Dalit community, including the victim’s own family. Public outrage eventually forced the matter to be handed over to the CBI, leading to the trial and conviction of thirteen accused.
"Despite Hostility, the Court Must Extract the Truth to Advance the Cause of Justice"
A major contention by the appellants was the reliance by the courts below on the testimony of witnesses who had partly turned hostile. Rejecting this, the Supreme Court held, quoting from its earlier judgments, that: “The testimony of a hostile witness cannot be discarded wholly. It is for the Court to assess which parts are reliable and corroborated by other evidence.”

The Court relied heavily on the depositions of PW-1 (Samikannu), PW-2 (Velmurugan), PW-3 (Palanivel), PW-15 (Tamilarasi), and most crucially, PW-49 (Chinnapillai) — the step-mother of Murugesan, who was an eyewitness to the administration of poison. Despite minor discrepancies, the Court found their evidence consistent on material particulars and sufficient to sustain convictions.

The Court quoted: “The duty of a Trial Court is to discover the truth. Whatever evidence is there before the Court must be examined, tested, corroborated when necessary, before a verdict is given.”

It observed that the term 'hostile witness' is not even found in the Evidence Act, and a witness’s evidence remains part of the record unless it is wholly untrustworthy — a principle long established but often misunderstood.

"The Investigating Officer Did Not Investigate; He Manufactured Evidence": Court on Police Misconduct
The Supreme Court castigated the local police, particularly A-15 (Inspector M. Sellamuthu), for gross misconduct. It held: "Instead of collecting evidence, A-15 manufactured evidence and tried to implicate the innocent and set the guilty loose."

The Court noted how A-15 orchestrated a fabricated extra-judicial confession allegedly by the girl's father, A-1, and registered a misleading FIR after a nine-day delay. This was done only after political and media pressure built up.
Referring to Sections 154, 156, and 157 of the CrPC, the Court observed: “The moment police receive information regarding a cognizable offence, it is mandatory to register an FIR and investigate. Delay and refusal here are not merely lapses; they are crimes.”

The judgment sharply distinguished the roles of A-14 and A-15. While A-14 was guilty of dereliction of duty under Section 217 IPC and Section 4 of the SC/ST Act, A-15’s actions were far graver, amounting to framing innocent Dalits and covering up caste atrocities, warranting confirmation of his life sentence.

The Court declared that the principle of 'falsus in uno, falsus in omnibus' — false in one thing, false in everything — does not apply in Indian law. Witness testimony must be weighed carefully, extracting reliable parts corroborated by other evidence.

Highlighting the duty of courts to act proactively, the Bench said: “A trial judge must cease to be a mere umpire and must become a participant in the trial to unearth the truth.”
It upheld the importance of powers under Section 311 CrPC and Section 165 of the Evidence Act, noting that summoning PW-49 mid-trial was entirely proper, necessary, and within the spirit of the law to ensure justice.
The Court further cited Lalita Kumari v. State of U.P. to reiterate that police officers are bound by law to register FIRs immediately upon information of cognizable offences. Failure to do so is not a technical violation, but a fundamental betrayal of their duty.

Summing up the case, the Court stated: “The horror of caste-based honour killings cannot be underestimated. It is the duty of every organ of the State — including the judiciary — to act decisively against such barbarity.”
The appeals were dismissed in their entirety. Convictions were upheld with minor modifications, and appellants on bail were ordered to surrender within two weeks.

The Court also awarded an additional ₹5 lakh as compensation to the family of Murugesan, payable by the State of Tamil Nadu, over and above previous compensation amounts.

Date of Decision: 28 April 2025