Bengaluru Court Pardons Accused Pradosh Rao, Makes Him Approver in Renukaswamy Murder

In a significant procedural development, the 59th City Civil and Sessions Court in Bengaluru has granted pardon to accused No. 14, Pradosh S Rao, allowing him to become an approver in the high-profile Renukaswamy murder case. The order, passed by Judge Sujata Madivalappa Sambrani, transforms Pradosh from a co-accused into a prosecution witness, a move that could substantially alter the trajectory of the trial against Kannada actor Darshan and several other accused individuals. As the legal community watches closely, the implications for the prosecution’s case and the defence strategy are profound, given that an approver’s testimony can serve as critical corroborative evidence.

Background: The Renukaswamy Murder Case

The case involves the murder of Renukaswamy, a 33-year-old man, allegedly at the behest of actor Darshan and others. The prosecution has assembled a body of circumstantial evidence, but direct evidence linking the accused to the crime has been limited. Pradosh Rao, the 14th accused, was initially charged alongside Darshan and others. His role, according to his application to the court, involved being present at the crime scene and attempting to intervene in the assault. He further claimed that Darshan threatened to kill himself if Pradosh did not assist in covering up the incident, including the disposal of the body. These assertions, if repeated under oath as an approver, could provide the prosecution with an insider’s narrative that had been missing.

Key Developments: Court Grants Pardon Under Section 343 BNSS

The court’s decision to tender pardon to Pradosh Rao is grounded in Section 343 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), which empowers a competent court to pardon an accomplice in serious offences subject to conditions. The provision is designed to incentivize full and truthful disclosure by a co-accused in exchange for immunity from prosecution. As one public prosecutor explained on condition of anonymity, “An approver is a co-accused in a crime who turns witness for the prosecution and agrees to make a full and truthful disclosure about the offence and the involvement of other accused in return for pardon.” The court’s order explicitly conditions the pardon on Pradosh’s complete honesty; any false information, concealment of facts, or non-compliance could result in the withdrawal of the pardon and his reversion to accused status.

The prosecution, represented by Special Public Prosecutor Prasanna P Kumar, supported Pradosh’s application. The defence, led by actor Darshan (Accused No. 2), had opposed the move, arguing that the grounds in Pradosh’s application were prejudicial. Darshan had earlier challenged the application before the Karnataka High Court, which declined to intervene at that stage, noting that the trial court had yet to decide on the pardon. Now, with the trial court’s order in place, Pradosh will remain in judicial custody until the trial concludes, but his role shifts from defence to prosecution witness.

Legal Analysis: The Role and Risks of an Approver

Turning an accused into an approver is a well-established but delicate mechanism in criminal law. Senior advocate Shyamsundar MS explained the typical scenario: “If there are 10 accused in a crime and one of them has a relatively lesser role, such as driving the car and being present at the crime scene, that person may become an approver. His or her statement can then serve as corroborative evidence.” In this case, Pradosh’s alleged lesser role—being present, attempting to stop the assault, and later participating in disposal—fits this pattern.

For the prosecution, the approver’s statement can bridge gaps in circumstantial evidence. As the advocate noted, “The police may have collected circumstantial evidence, but if there is lack of direct evidence, the approver’s statement, along with other supporting evidence, can strengthen the prosecution’s case.” Pradosh’s detailed account, as outlined in his application, includes specific interactions with Darshan and the sequence of events after the murder. If his testimony remains consistent, it could corroborate forensic evidence, witness accounts, and digital trails.

However, the defence is not left without recourse. The defence team representing Darshan and others can attack Pradosh’s credibility on multiple fronts. They can argue that his testimony is motivated by a desire to escape punishment—a classic impeachment strategy. Cross-examination will focus on inconsistencies between his earlier statements, the application, and his pending approver statement. The court has already clarified that the approver’s evidence will not automatically lead to conviction; it must be weighed alongside all other material evidence. As a senior lawyer noted, “The court will not simply convict anyone only because an approver has given a statement. The approver’s evidence will have to be assessed along with other evidence available in the case.”

Impact on the Trial and Legal Practice

This development has immediate and far-reaching effects on the Renukaswamy murder trial. The recording of Pradosh’s approver statement is expected next week, after the ongoing cross-examination of another witness is completed. Once recorded, the statement becomes a critical piece of evidence. Legal professionals following the case recognise that while an approver can bolster the prosecution, it also introduces a witness whose reliability is inherently suspect. The trial court will apply the standard caution: convictions cannot be based solely on approver testimony unless it is corroborated by independent evidence.

From a broader legal practice perspective, the case illustrates the strategic use of Section 343 BNSS. Prosecutors in complex cases—especially those involving multiple accused and limited direct evidence—often seek to turn an accused with knowledge of the inner workings of the crime. The conditions attached to the pardon—full disclosure, truthfulness, and the risk of perjury—serve as checks against manipulation. If Pradosh fails to cooperate, the prosecution can seek action against him, including a separate perjury trial.

For the defence, this becomes a test of cross-examination skills. The advocate for Darshan will likely attempt to show that Pradosh’s version is self-serving, exaggerated, or contradicted by other evidence. The Karnataka High Court’s earlier observation that one co-accused cannot oppose another’s application to become an approver underscores the procedural autonomy of each accused. However, the trial court retains discretion to evaluate the approver’s credibility at every stage.

Conclusion: What This Means for Darshan and the Other Accused

While Pradosh Rao’s status as an approver does not guarantee a conviction for Darshan or anyone else, it undeniably strengthens the prosecution’s hand. The court will now have the benefit of a participant’s account of the events. Yet, as legal experts caution, the approver’s statement is not a silver bullet. The defence will rigorously challenge its reliability, and the court must assess it against the totality of evidence, including medical reports, digital evidence, and other witness testimony.

The immediate focus is on the recording of Pradosh’s approver statement, which will set the tone for the next phase of the trial. Legal professionals across Karnataka are watching this case as a textbook example of how the approver mechanism operates in high-stakes criminal litigation. For the accused, the message is clear: the turning of a co-accused into a prosecution witness can be a game-changer, but the ultimate outcome hinges on the strength of corroborative evidence and the court’s impartial assessment of all material before it.