VidhiSangh

Supreme Court of India · 15/07/2025

KATTAVELLAI @ DEVAKAR versus STATE OF TAMILNADU

[2025] 7 S.C.R. 984 · 2025 INSC 845

AI-generated headnote. Verify against the judgment before relying on it. Paragraph numbers refer to the judgment.

Summary

A death sentence for the murder of a young couple and rape of the woman at Suruli Falls, resting wholly on circumstantial evidence, was set aside and the appellant acquitted: the star witness's six-day silence was not the conduct of a reasonable man, the arrest had no recorded basis, the police confessions were unreliable, the recovered articles were never forensically linked to the crime, the DNA evidence failed for an unexplained 41-day delay and a broken chain of custody, and the test identification parade was vitiated because the witness had seen the accused and been told by the police that he was the culprit. The Court issued binding directions on the collection, transport, storage and chain-of-custody documentation of DNA samples.

Issues

  1. Whether the circumstances relied on (arrival of the victims at the spot, last seen, arrest, confession and recovery, DNA evidence of rape, motive and test identification parade) formed a complete chain proving the appellant's guilt beyond reasonable doubt.
  2. Whether the last-seen evidence of PW-5, who stayed silent for six days, and of a forest guide who saw the appellant with a sickle, was reliable.
  3. Whether DNA evidence can be relied on where there is unexplained delay in sending samples to the laboratory and the chain of custody is not established.
  4. Whether a test identification parade is of any value where the witness saw the accused at the police station and was told by the police that he had committed the crime.
  5. What procedure investigating agencies must follow for the collection, transport, storage and custody of DNA samples.

Provisions considered

Held

Result

Appeal allowed; conviction and death sentence vacated and the appellant directed to be released forthwith if not required in any other case; directions on handling and chain of custody of DNA evidence issued to apply henceforth in all cases, with the Registry to send the judgment to all High Courts and Directors General of Police.

Judgment PDF: Supreme Court of India, [2025] 7 S.C.R. 984.