Supreme Court of India establishes the importance of motive and corroborative evidence in murder cases and converts the death sentence to 20 years of rigorous imprisonment.
In a landmark judgement delivered on October 16, 2024, the Supreme Court of India ruled that while the crime committed by Eknath Kisan Kumbharkar, the appellant, was grave and unpardonable, it did not fall under the “rarest of rare” category to justify a death sentence. The court emphasized the importance of motive and corroborative evidence in murder trials and converted the death sentence awarded by the lower courts to 20 years of rigorous imprisonment without remission.
Factual Matrix of the Murder case:
Eknath Kisan Kumbharkar was convicted of murdering his pregnant daughter, Pramila, after she married outside their caste in 2013, an act that deeply angered him. The prosecution accused Kumbharkar of luring his daughter into an autorickshaw under the pretext of taking her to see her grandmother, where he strangled her to death. Pramila, who was nine months pregnant, was taken to a hospital but was declared dead upon arrival.
The trial court found Kumbharkar guilty under Sections 302 (murder), 316 (causing death of an unborn child), and 364 (kidnapping) of the Indian Penal Code (IPC) and sentenced him to death. The Bombay High Court upheld the conviction and the death sentence, prompting Kumbharkar to appeal to the Supreme Court.
Prosecution’s case in the Supreme Court
The prosecution’s case relied heavily on the testimony of key witnesses. Pramod Ahire (PW2), the autorickshaw driver, provided a detailed account of how Kumbharkar coaxed him into driving to the house of Pramila’s in-laws, under the pretext of taking her to see her grandmother. Ahire witnessed Kumbharkar strangling Pramila with a rope in the autorickshaw, an act that led to her death.
Pramila’s mother, Aruna Kumbharkar (PW1), testified that Kumbharkar had been angry ever since his daughter married a man from a lower caste, tarnishing his reputation in their community. She further stated that Kumbharkar had a long-standing grudge against his daughter due to the inter-caste marriage.
The testimony of Pramila’s mother-in-law, Sangita Kamble (PW3), corroborated the events leading up to Pramila’s death. Kamble testified that Kumbharkar assured her he would bring Pramila back within a few hours for a medical appointment, a promise he did not keep.
Defense’s Argument
The defense argued that there was no clear motive for Kumbharkar to commit the murder. It was emphasized that despite the inter-caste marriage, Kumbharkar had visited Pramila’s house on multiple occasions without conflict. Additionally, the defense highlighted inconsistencies in the prosecution’s case, particularly regarding the credibility of the witnesses. The defense argued that the testimonies of PW2 and PW3 were unreliable and that independent witnesses, such as the tea stall owner near the crime scene, were not examined by the prosecution.
The defense further argued that the case was built on circumstantial evidence, and there were no clear signs of premeditation or intent. They also raised the issue of a previous financial dispute between Kumbharkar and PW2, suggesting that this was a case of false implication.
Court’s Findings
The Supreme Court, after evaluating the evidence, concluded that the prosecution had successfully established Kumbharkar’s motive for the crime. The court found the testimonies of the critical witnesses, including PW1, PW2, and PW3, to be credible and consistent with the chain of events leading up to the murder.
The court rejected the defense’s argument about the absence of motive, noting that Kumbharkar’s grudge against his daughter for marrying outside their caste had been sufficiently established. The court also dismissed the claim that the case was based on unreliable witnesses, stating that the testimony of a single eyewitness (PW2) was enough to secure a conviction when corroborated by other evidence.
The court noted that while there were some minor discrepancies in the prosecution’s case, these did not detract from the overall reliability of the witnesses. The court referenced previous cases to assert that minor contradictions in witness testimonies do not invalidate the entire case, especially when the evidence points strongly to the guilt of the accused.
Sentencing and Mitigating Factors
Despite affirming Kumbharkar’s conviction, the Supreme Court considered several mitigating factors before ruling on the death sentence. Kumbharkar had spent 11 years in prison, during which time he displayed good behavior. He came from a poor, nomadic community, had no prior criminal record, and had faced significant hardships throughout his life, including poverty and parental neglect.
The court also took into account medical reports that revealed Kumbharkar’s declining health. He had undergone an angioplasty in 2014 and suffered a stroke in 2021, leaving him with speech impairments and cognitive issues. His psychological evaluation indicated that he suffered from mental illness, which was exacerbated by his time in prison.
Citing the doctrine of the “rarest of rare” cases, the court concluded that while Kumbharkar’s crime was heinous, it did not warrant the death penalty. The court emphasized that the death penalty should only be imposed when there is no possibility of reform, which was not the case for Kumbharkar.
The Supreme Court, while upholding Kumbharkar’s conviction, commuted the death sentence to 20 years of rigorous imprisonment without the possibility of remission. The court concluded that the crime, though grave, did not meet the strict criteria for the imposition of the death penalty, particularly given the mitigating circumstances of Kumbharkar’s life and health. The judgment reaffirms the principle that the death penalty should be reserved for only the most exceptional cases where no other punishment would suffice.
Check out these links to find other landmark judgements of Supreme Court:
