Renuka Prasad v. The State
In a dramatic turn of events, the Supreme Court of India delivered a judgment in Renuka Prasad v. The State on May 9, 2025, overturning the convictions of six accused in a brutal murder case. The ruling highlighted the fragility of criminal prosecutions when witnesses turn hostile and the dangers of relying solely on police testimony. Here’s the story of how the case unfolded, from the crime to the final verdict.
The Crime: A Brutal Murder
On the evening of April 28, 2011, Ramkrishna, an employee of an educational institution, was hacked to death while taking a stroll with his 15-year-old son, PW8. The assailants emerged from bushes, attacked Ramkrishna, and fled. The boy immediately alerted relatives, and the victim was rushed to the hospital but succumbed to his injuries. The first information statement (FIS) was lodged by PW8, leading to a police investigation.
The prosecution alleged that the murder was orchestrated by A1, a prominent entrepreneur, due to a bitter sibling rivalry over family assets. Ramkrishna, who had worked for A1, later joined an institution managed by A1’s brother, PW4, allegedly fueling A1’s enmity. The prosecution claimed A1 conspired with his employees (A2-A4) and hired contract killers (A5-A6) through an advocate (A7) to execute the murder.
The Trial: A Collapse of the Prosecution’s Case
The trial saw 87 witnesses, including eye-witnesses, family members, and colleagues, take the stand. Shockingly, 71 of them turned hostile, disowning their prior statements to the police. Key witnesses like PW8, the victim’s son, failed to identify the assailants or the weapons recovered. PW1 and PW9, who allegedly saw the attackers flee, denied their presence or gave inconsistent accounts. Even the victim’s wife, PW10, retracted her statement about A1’s threats.
The motive—rooted in sibling rivalry—collapsed when PW4, A1’s brother, denied any enmity or writing a letter (MO40) that supposedly detailed the feud. Witnesses meant to prove conspiracy, preparation (like buying weapons), and post-crime events also recanted. The prosecution’s case hinged almost entirely on police testimony and recoveries, including cash, weapons, and blood-stained clothes.
Despite the hostile witnesses, the Trial Court acquitted all accused, citing insufficient evidence. The prosecution’s elaborate narrative, built on Section 161 statements (recorded during investigation), crumbled in court.
The High Court’s Reversal: Conviction on Police Testimony
The State appealed, and the Division Bench of the High Court reversed the acquittal, convicting A1-A6 under Section 302 (murder) read with Section 120-B (criminal conspiracy) of the IPC. The court relied heavily on the testimonies of the Investigating Officers (PW83, PW84, PW87), who affirmed the witnesses’ earlier statements under Section 161. The High Court reasoned:
- Police Testimony Can Be Reliable: Citing precedents like State v. Sunil and Rizwan Khan, the court held that police evidence need not always be distrusted, especially for recoveries under Section 27 of the Evidence Act (discovery based on accused’s information).
- Recoveries Linked to the Crime: The court noted recoveries of blood-stained clothes (matching the victim’s blood group) and weapons, though the panch witnesses turned hostile.
- Motive and Conspiracy: Despite witnesses resiling, the court inferred motive from the sibling rivalry and conspiracy from the accused’s voluntary statements. A7, the advocate, was acquitted due to lack of evidence.
The Supreme Court’s Verdict: Restoring Acquittal
The accused appealed to the Supreme Court, which delivered a scathing critique of the High Court’s reasoning. Justices Sudhanshu Dhulia and K. Vinod Chandran underscored fundamental legal principles:
- Hostile Witnesses Cannot Be Ignored: The prosecution’s case collapsed because witnesses denied their earlier statements. The court cannot substitute their testimony with police versions of what they might have said.
- Section 161 Statements Are Not Evidence: Under Section 162 CrPC, statements to police during investigation are inadmissible as substantive evidence. They can only be used to contradict witnesses, not to prove guilt.
- Recoveries Must Connect to the Crime: The blood-stained clothes and weapons were recovered based on A3’s confession, but A3 was not the perpetrator. The court cited Pulukuri Kottaya to stress that recoveries under Section 27 must distinctly relate to the crime and cannot include confessions about the crime itself.
- No Proof of Conspiracy: The alleged meetings and money transfers were not proven independently. The farm where weapons were recovered wasn’t even proven to belong to A1.
- Presumption of Innocence: The Trial Court’s acquittal was based on a reasonable view of the evidence. The High Court erred in reversing it without stronger grounds.
The Supreme Court concluded that the High Court’s conviction was based on “mere surmises and conjectures” and restored the Trial Court’s acquittal. The accused were ordered to be released if not wanted in other cases.
About the Author: Neeraj Gogia, Advocate, 9891800100, specializing in criminal law jurisprudence. This article is intended for informational purposes only and does not constitute legal advice.
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