VidhiSangh

Supreme Court of India · 03/01/2024

PERUMAL RAJA @ PERUMAL versus STATE, REP. BY INSPECTOR OF POLICE

[2024] 1 S.C.R. 87 · 2024 INSC 13

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Summary

The Supreme Court upheld murder and evidence-disappearance convictions on a circumstantial chain including the appellant’s disclosure, recovery of concealed remains, forensic identification and motive. Section 27 custody does not require formal arrest in the particular case. An adverse inference from unexplained special knowledge reinforced, rather than replaced, the prosecution’s proof.

Issues

  1. Whether discovery evidence was admissible when the appellant was detained in another case and how narrowly the disclosure must be used.
  2. Whether the recoveries and identification established a complete circumstantial chain.
  3. What effect followed from the appellant’s failure to explain special knowledge and from acquittals in separate proceedings or of co-accused.

Provisions considered

Held

Result

Appeal dismissed. Convictions under Sections 302 and 201 IPC upheld, with life imprisonment and Rs.5,000 fine for murder and three years’ rigorous imprisonment and Rs.3,000 fine for disappearance of evidence.

Judgment PDF: Supreme Court of India, [2024] 1 S.C.R. 87.