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by Admin
05 December 2025 4:19 PM
“This is a classic case of investigating agencies being under public pressure, dishing out a charge sheet just to quell public angst” — Karnataka High Court tears apart murder conviction, citing complete breakdown in evidentiary chain
Karnataka High Court delivered a landmark judgment in Criminal Appeals, setting aside the conviction of four men accused in a gruesome triple murder that had shocked Bengaluru in 2009. The Court held that the prosecution had failed to prove even a single circumstance in the chain of evidence beyond reasonable doubt, observing that the trial court’s conviction rested on “mechanical reasoning,” unreliable witnesses, and procedural lapses that rendered the entire investigation legally worthless. The Court's searing indictment of investigative shortcuts underscores the constitutional mandate of proof beyond reasonable doubt, not public pressure or prosecutorial overreach.
The appeals were filed by Lokesh, Ramesh, Murali and Bhaskar, who had been convicted under Sections 120B, 109, 449, 201, 302 and 380 read with 34 of the IPC, and sentenced to life imprisonment by the trial court on March 11, 2019. However, the High Court concluded that the prosecution failed to prove motive, failed to link the accused to the scene of the crime through scientific or testimonial evidence, and relied on contradictory or hostile witnesses. The Court also dismissed the State’s appeal seeking enhancement of sentence, labelling the trial court’s findings as unsustainable in law and contrary to the principles of criminal justice.
"Courts Cannot Convict on Suspicion, However Grave — Guilt Must Rest on Legally Admissible Proof"
“The prosecution has not proved even a single circumstance forming part of the chain of events” — Court demolishes circumstantial case for lack of foundational facts
The case concerned the murder of Rahul Das, his wife Pushpalatha, and their minor daughter Agnisha, who were found dead in their home under suspicious circumstances. The prosecution alleged that Ramesh, a colleague of Pushpalatha, was in a relationship with her and conspired with Lokesh, Murali and Bhaskar to kill her husband and daughter to facilitate their continued affair and rob the family.
Rejecting the prosecution’s theory of conspiracy and motive, the Court stated that “none of the prosecution witnesses, including the so-called close friends and relatives, stated anything about any dispute between the deceased or any enmity or plan to commit the offence.” The supposed illicit relationship and conspiracy lacked evidentiary support, and the prosecution had “utterly failed to prove the genesis of the alleged crime.”
“Recovery Evidence is a Legal Fiction Without Witnesses — Police Cannot Manufacture Guilt”
The High Court found the entire recovery process of stolen items such as jewellery, phones, cash and liquor bottles to be unreliable. Almost all pancha witnesses, including PWs 14, 15, 28, 29, 33 and 34, either turned hostile or admitted that they did not witness the recovery and merely signed panchanamas on police direction.
“Not a single recovered article has been proven to belong to the deceased or from the scene of offence,” the Court noted, adding that these recoveries were staged to create a false impression of guilt.
The use of "professional witnesses" from the Protection Committee as panchas, who were working closely with police, further eroded the credibility of the investigation. The Court pointed out that such practices defeat the purpose of independent corroboration under Section 27 of the Evidence Act.
“Last Seen Must Be Last Proven Fact — Suspicion Cannot Substitute Certainty in Criminal Law”
The prosecution’s reliance on the last seen theory was found to be completely unsustainable. Witnesses PW6 and PW27, cited as having last seen the accused near the house of the deceased on the day of the incident, had turned hostile and contradicted their earlier statements.
The Court reminded that the law on last seen, as laid down by the Supreme Court in State of U.P. v. Satish, requires a close time proximity between the last sighting and the death, and such a link was entirely missing in this case.
“In the absence of a narrow time gap and credible testimony, the theory of last seen cannot be pressed into service to establish guilt,” the Court held.
“DNA Evidence Requires Scientific Integrity — No Chain of Custody, No Legal Value”
The prosecution’s most high-stakes claim — that the hair samples collected from the scene matched the DNA of accused Nos. 3 and 4 — was dismantled by the High Court for glaring procedural flaws.
It noted that the source of the hair was not proved. The investigating officer and the forensic officer gave contradictory versions about who collected the hair and from where. There were no photographs, no packaging details, and no documentation of chain of custody.
The Court observed: “DNA evidence may be highly useful for investigation, but in a court of law, it must meet strict legal standards… Here, it completely fails to do so.”
Relying on Rahul v. State of Delhi, Kettavellai v. State of Tamil Nadu, and Manoj v. State of Madhya Pradesh, the Court reiterated that DNA evidence without proper preservation and proof of origin cannot sustain conviction.
“Fingerprints Without Legal Process Are Worthless — Whisky Bottle Not Even Mentioned in Initial Report”
The prosecution attempted to tie accused to the crime through fingerprints allegedly lifted from a whisky bottle and tumblers found at the crime scene. However, the Court noted that the whisky bottle was not even mentioned in the initial FSL scene report and its very presence was unproved.
Further, there was no mahazar, no documentation of the lifting process, and no photographs showing the actual fingerprint lifting. Witnesses to this process also turned hostile, and the Court noted that even the guidelines under the Karnataka Police Manual were violated.
“In absence of basic procedural compliance, the fingerprint evidence cannot be relied upon,” the Court ruled.
“Trial Court Judgment is a Mere Reproduction of Prosecution — No Independent Judicial Application”
The High Court found the trial court’s 2019 judgment to be lacking in both legal reasoning and factual analysis. It observed that the trial judge had “mechanically extracted depositions without analysis,” failed to apply the law on circumstantial evidence, and rendered findings that were inconsistent with the record.
“There is no proper marshaling of evidence or application of mind to the principles governing criminal jurisprudence,” the Court said, calling the judgment unreasoned and unsustainable.
“Liberty Cannot Be Sacrificed to Expediency — Prolonged Incarceration Without Legal Basis Violates Article 21”
In its concluding remarks, the Division Bench composed of Justice K.S. Mudagal and Justice M.G.S. Kamal emphasized the cost of wrongful prosecution and prolonged incarceration, observing:
“This is a classic case of investigating agencies being under public pressure, dishing out a charge sheet just to quell public angst. The role of the investigating agency in such cases is far from satisfactory.”
The Court reiterated that clean acquittals after long imprisonment may trigger Article 21 violations and even raise claims for compensation under public law remedies. Citing the recent Supreme Court ruling in Kettavellai v. State of Tamil Nadu (2025) and V. Senthil Balaji v. ED, the Court underlined that the criminal justice system must prioritise legality over sensationalism.
The High Court allowed all criminal appeals, set aside the trial court's conviction dated March 11, 2019, and acquitted all four accused of charges under Sections 120B, 109, 449, 201, 302 and 380 read with Section 34 of the IPC. The State’s appeal seeking enhancement of sentence was dismissed. The Court also directed that a copy of this judgment be circulated to all trial courts by the Registrar General for judicial education.
Date of Decision: 04 October 2025
