Sessions Court Lacks Jurisdiction to Impose ‘Life Till Natural Death’ Sentence: Karnataka High Court

“The power to impose punishment of imprisonment for life without remission was conferred only on the Constitutional Courts and not on the Sessions Courts.” — In a seminal ruling the High Court of Karnataka, comprising Justice H.P. Sandesh and Justice Venkatesh Naik T, upheld the conviction of an accused for the brutal murder of a 3½-year-old child but modified the sentence, holding that the Trial Court exceeded its jurisdiction by imposing life imprisonment "until natural death."

The Case of the Poisoned Sambar

The appeal arose from a judgment by the V Additional District and Sessions Judge, Shivamogga, convicting Rudresh @ Rudraiah for the murder of a toddler, Sujay. The prosecution’s case was harrowing: the accused, harboring deep-seated animosity towards the complainant (the child’s mother) and her family for reprimanding his theft and misconduct at the Moolegadde Mutt, executed a calculated revenge plot.

On the night of April 10, 2017, the accused mixed Clonazepam (sleeping pills) into the sambar prepared for the devotees. While the adults suffered dizziness, the accused kidnapped the sedated child, administered more sleeping pills, and drowned him in a stream behind the Mutt.

“The motive for committing the murder is only hatredness against P.W.1, mother of the deceased, P.W.2, the grand-mother of the deceased and P.W.4, the great grand-mother of the deceased.”

Circumstantial Evidence: The ‘Panchasheela’ of Proof

As there were no eyewitnesses to the actual act of drowning, the case rested entirely on circumstantial evidence. The defense counsel vehemently argued that the chain of circumstances was broken, citing the lack of direct evidence and alleged discrepancies in the FSL reports regarding other devotees who consumed the food.

However, the High Court meticulously reconstructed the chain of events, applying the "five golden principles" (panchasheela) of circumstantial evidence. The Court found the prosecution had successfully established:

1. Motive: The accused’s history of theft and the resultant ill-will towards the victim's family.

2. Preparation: The testimony of the medical shop owner (PW9), who confirmed the accused purchased Clonazepam 0.5 mg tablets, corroborated by receipts (Ex.P31).

3. Opportunity: The accused’s presence at the Mutt and access to the food.

Section 27 Evidence Act: Discovery of the Body

A contentious point in the appeal was the recovery of the child's body. The defense relied on Putai v. State of Uttar Pradesh (2025), arguing that the body was found in an open space accessible to all, thereby negating the evidentiary value of the discovery under Section 27 of the Indian Evidence Act.

The High Court rejected this contention. Relying on the testimony of the Investigating Officer and independent panch witnesses, the Bench noted that the body was recovered from an isolated stream surrounded by trees, hidden from general view, and discovered solely based on the accused's voluntary disclosure statement.

“The recovery of the dead body is from an isolated place i.e., no one can visible the same... Section 27 of the Evidence Act is aptly applicable to the case on hand.”

Forensic Corroboration

The medical evidence proved fatal to the defense. The Post Mortem report and FSL analysis confirmed the presence of Clonazepam in the child’s viscera. Crucially, the absence of diatoms in the water sample and the child's body indicated that the child was likely unconscious or dead before being thrown into the water, corroborating the theory of prior sedation. The Court dismissed the defense's argument regarding the negative FSL report for other devotees, noting the delay in blood sample collection for the survivors allowed for the metabolism of the drug.

Sentencing Jurisprudence: The Constitutional Bar

While the High Court confirmed the conviction under Section 302 IPC, it found a grave legal error in the sentencing. The Sessions Court had sentenced the accused to life imprisonment "until his natural death."

Referring to the Supreme Court’s recent ruling in Kiran v. State of Karnataka (2025 SCC OnLine SC 2863), the High Court clarified that the power to impose a special category of sentence—life imprisonment without remission/set-off—is the exclusive prerogative of the Constitutional Courts (High Courts and the Supreme Court). A Sessions Court does not possess the jurisdiction to foreclose the statutory right of an accused to seek remission under the Cr.P.C.

Consequently, while the conviction was upheld, the sentence was modified from "life imprisonment until natural death" to "imprisonment for life."

Date of Decision: January 23, 2026