LexRAMESH A. NAIKA versus THE REGISTRAR GENERAL, HIGH COURT OF KARNATAKA ETC.
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[2025] 2 S.C.R. 1721 : 2025 INSC 303 Ramesh A. Naika v. The Registrar General, High Court of Karnataka Etc. (Criminal Appeal No(s). 877-878 of 2020) 13 February 2025 [Vikram Nath, Sanjay Karol* and Sandeep Mehta, JJ.] Issue for Consideration Appellant-R, a bank manager, was convicted of murdering his two minor children, along with his sister-in-law and mother-in- law, in June 2010. His motive stemmed from disapproval of his sister-in-law’s relationship, which his wife and her family supported. On 16.06.2010, he allegedly killed his sister-in-law and mother-in- law at his house in Tumkur and disposed of their bodies in a sump tank. The next day, he took his children to a water tank in Mangalore and drowned them. He later sent messages to his wife, suggesting she end her life. His wife reported the matter, leading to his arrest. The Trial Court sentenced him to death. It was held by the Trial Court that the circumstances did indeed point to the guilt of the appellant and that the defence could not point to any alternative hypothesis to establish his innocence. He was in the company of the deceased children and none else, hence the application of the last seen theory - he had to explain that since they were with him, and a short time later they were found to be deceased, it was incumbent upon him to furnish an explanation. Since none is forthcoming, all circumstances considered, the chain is completed. The conviction by the Trial Court and the sentence of death penalty imposed on the accused was upheld by the Karnataka High Court. Whether, in the facts and circumstances of the case, the sentence of death penalty imposed on the Appellant by the Trial Court confirmed by the High Court can be interfered with. Headnotes† Penal Code, 1860 – Section 302 – Murder of two minor children – Conviction under Section 302 confirmed, whereas death penalty commuted to life sentence – Case of circumstantial evidence: * Author 1722 [2025] 2 S.C.R. Supreme Court Reports Held: It is clearly a case of circumstantial evidence – The principles to be applied in consideration of the evidence have been christened the ‘Panchsheel Principles’ detailed in the Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116 judgment – Both the Courts below have found the circumstances to be established against the appellant-convict – Held that there is no error in the findings recorded by both the Courts qua the guilt of the Appellant and the judgment on conviction. [Para 6] Criminal Procedure Code – Sentencing – Mitigating circumstances relied upon to commute death penalty to life sentence till remainder of life without remission: Held: To enable parties to adequately prepare, it is desirable that there be some gap between the pronouncement of judgment, and the hearing on sentencing – It has, however, been held that the point of focus in a sentencing hearing is quality and reliability of assistance and closeness of time, itself would not render the sentence handed down, susceptible to doubt – The mitigating circumstances considered including Appellant’s lack of prior criminal record, his good relations with the deceased individuals before the crime, and his initial act of securing a job for his sister-in-law, which indicated positive intentions toward the family – The absence of criminal intent as a mitigating circumstance was negated by the Court. The rule only is that the circumstantial evidence ought to be unimpeachable, and the matter at hand be an exceptional case, or the evidence be so convincing that the option of imposition of any other penalty stands foreclosed in the judicial mind – Therefore, non-consideration of this ground cannot be said to be damaging to the sanctity of the sentencing order – On the basis of mitigating circumstances, the death penalty commuted to life sentence till the remainder of life without remission. [Paras 7, 10, 13] List of Websites https://home.nps.gov/liho/learn/historyculture/alincolnbio.htm; http://www.merriam-webster.com/dictionary/antecedent List of Acts Penal Code, 1860; Code of Criminal Procedure, 1973. [2025] 2 S.C.R. 1723 Ramesh A. Naika v. The Registrar General, High Court of Karnataka Etc. List of Keywords Death Penalty; Murder; Panchsheel Principles. Case Arising From CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No(s). 877-878 of 2020 From the Judgment and Order dated 22.09.2017 of the High Court of Karnataka at Bengaluru in CRLRC
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