Supreme Court Quashes Convictions, Acquits Two Accused in Murder Case Citing Improbable Eye‑witness Account

A bench of Justice Vikram Nath and Justice Sandeep Mehta heard appeals against the Madras High Court’s judgment confirming convictions under Sections 302 and 34 IPC arising from two criminal trials; the appeals challenged the Trial Court and High Court findings that relied chiefly on evidence of two interested eyewitnesses. The appeals originated from SLP (Crl.) Nos. 1693 and 3816 of 2025 and arose from Criminal Appeal proceedings against judgments dated 04.03.2020 (Trial Court) and 10.09.2024 (Madras High Court).

The Court allowed the appeals and acquitted the appellants, holding that the prosecution failed to prove guilt beyond reasonable doubt. The bench emphasised that the testimonies of the son and wife of the deceased (PW‑1 and PW‑2) required “greater care and circumspection” and the presence of these witnesses at the scene was inherently improbable. The Court noted that the two witnesses claimed to have covered a distance of about 16 kilometres by bicycle within thirty minutes and that their conduct after the incident lacked satisfactory explanation. The Court observed that “it seems exceedingly improbable and raises huge doubts about the presence of PW‑1 and PW‑2 at the crime spot.” It further held that “This brings forth an inherent improbability in the prosecution story which goes to the root of the case altogether and cannot be overlooked.” The Court, in its reasoning, observed: “From the above discussion, it cannot be said that the prosecution has discharged its burden of establishing the guilt of the accused persons beyond reasonable doubt. In such circumstances, the accused persons have to be declared innocent and there is no alternative to such a conclusion.” Accordingly, the Trial Court and High Court judgments were quashed and set aside, and the appellants were acquitted and ordered to be released forthwith unless required in connection with any other case.

Background The criminal proceedings arose from the death of Edison Suvisedha Muthu on 14.04.2013. The prosecution alleged that Accused No.1 (A1) and Accused No.2 (A2) lured and murdered the deceased at a TASMAC shop, motivated by an earlier feud after the deceased had allegedly assaulted A1’s father. PW‑1 (the son) and PW‑2 (the wife) were the principal eyewitnesses who deposed that A2 took the deceased to the liquor shop and signalled A1 to attack; A1 then inflicted multiple injuries causing death. The prosecution relied on their ocular testimony, confessional statements leading to recovery of a motorcycle and an “aruval” (machete), and the post‑mortem report noting 26 injuries. The Trial Court convicted both accused persons and sentenced them to life imprisonment; the High Court affirmed.

On appeal, the accused contested the credibility and presence of PW‑1 and PW‑2, highlighting the improbability of traversing 16 km by bicycle in thirty minutes and their conduct of returning home before reporting to police despite a police station en route. The State relied on motive, consistency of the key witnesses, medical corroboration and recoveries. The Supreme Court analysed settled principles requiring heightened scrutiny of related/interested witnesses (citing Gangadhar Behera and other authorities) and examined inconsistencies and hostile statements by other on‑scene witnesses. The Court concluded that the improbability of the key witnesses’ presence, the hostility of other eyewitnesses, and the post‑mortem injuries pointing to multiple assailants created reasonable doubt that the accused alone committed the offence. The appeals were allowed, convictions quashed, and the appellants acquitted; pending applications stood disposed of.

Case Details: Case No.: 2025 INSC 880 Case Title: Esakkimuthu & Anr. v. State represented by The Inspector of Police (arising out of SLP (Crl.) Nos. 1693 and 3816 of 2025) Appearances: For the Petitioner(s): Mr. S. Nagamuthu, Senior Counsel For the Respondent(s): Mr. V. Krishnamurthy, Senior Counsel