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2026 Supreme(Mad) 36

IN THE HIGH COURT OF JUDICATURE AT MADRAS
P.VELMURUGAN, M.JOTHIRAMAN, JJ.
Madhesh – Appellant
Versus
State, Rep. by Inspector of Police, Nagarasampatti Police Station - Respondent 
Crl.A.No.561 of 2019
Decided On : 26-02-2026

Advocates Appeared:
For the Appellants : Mr. Arun Anbumani
For the Respondent: Mr. A. Damodaran, Additional Public Prosecutor Assisted by Ms. M. Arifa Thasneem.

A conviction for murder can be sustained based on the credible testimony of a single eyewitness, corroborated by medical evidence and circumstantial facts establishing motive.

Headnote:(A) Indian Penal Code, 1860 - Sections 302, 34 - Criminal Procedure Code, 1973 - Section 374(2) - Double murder - Conviction of accused upheld after finding sufficient evidence including motive and eyewitness accounts - Trial Court's judgment confirmed; no illegalities found. (Paras 1, 3, 34)

(B) Evidence Act, 1872 - Section 134 - Conviction can rest on a single witness' credible testimony even if uncorroborated; quality of evidence is paramount. (Paras 22, 25, 29)

(C) Medical Evidence - Correlation between injuries noted by medical examiner and witness accounts strengthens prosecution case. (Paras 24, 31, 32)

Facts of the case:
Two individuals were murdered by the accused, who had a long-standing enmity with the victims' family stemming from a land sale dispute. Witnesses testified that the accused attacked the victims with a billhook during a religious ceremony at the disputed land. (Paras 2.1, 10, 11, 32)

Findings of Court:
The evidence presented by eyewitnesses and recovery of material objects including the murder weapon, along with medical reports correlating the injuries to the accounts, led to the conclusion that the accused were guilty of murder. (Paras 30, 36)

Issues: Competence of eyewitness testimony in murder cases; consideration of motive and evidence; the role of medical evidence in corroborating eyewitness accounts. (Paras 3, 8)

Ratio Decidendi: The court held that the conviction was justified based on the credible testimony of the sole eyewitness and corroborated by medical evidence. It was reiterated that even a single reliable witness could lead to a conviction, provided the evidence is consistent and clear. (Paras 22, 34)

Result: Criminal Appeal dismissed; the appellants ordered to undergo the remainder of their sentence.

Table of Content
1. overview of the trial and convictions. (Para 1 , 1 , 2 , 2)
2. arguments related to fir delay and evidence suppression. (Para 4 , 4 , 5 , 6)
3. laws on witness testimony and corroboration. (Para 7 , 10)
4. motive and eyewitness testimony. (Para 8 , 9 , 11 , 12 , 13)
5. relevance of single eyewitness testimony. (Para 14 , 15)
6. inferences drawn from evidence and events. (Para 18 , 19)
7. recovery evidence supports the prosecution case. (Para 21)
8. medical evidence aligns with witness accounts of murder. (Para 22 , 23)
9. analysis of contradictions in witness statements. (Para 24 , 26)
10. comprehensive proof of the prosecution case. (Para 30 , 31)
11. final judgment and implications for the accused. (Para 34)

JUDGMENT :

M. JOTHIRAMAN, J.

The appellants / accused have preferred this Criminal Appeal as against the judgment dated 31.07.2019 made in S.C.No.262 of 2016 passed by the learned Additional Sessions Judge, Krishnagiri District, in and by which they were convicted and sentenced as under:

Rank of the AccusedConviction under SectionSentence of Imprisonment
A1 and A3302 r/w 34 IPCLife Imprisonment with a fine of Rs.25,000/- each, in default to undergo 3 months Simple Imprisonment
A2302 IPCLife Imprisonment with a fine of Rs.25,000/- in default to undergo 3 months Simple Imprisonment
A1 to A3506(ii) IPC7 years Rigorous Imprisonment and to pay a fine of Rs.10,000/- each, in default to undergo 3 months Simple Imprisonment.

The Trial Court further directed that out of the total fine amount of Rs.1,05,000/-, a sum of Rs.1,00,000/- was ordered to be paid as compensation to PW1 under Section 357 (1) CrPC and the sentences were ordered to run concurrently.

2. Brief case of the prosecution is as follows:

2.1. PW1 – Tmt.Chandra is the wife of the deceased Ramajayam and mother of the deceased Illayaraja. She deposed that for the past 20 years, enmity existed between the family of the accused and PW1’s family. The accused quarreled with PW1’s family when they were constructing the house and also there is enmity with regard to getting fish tender. One Dhanakodi S/o. M.R.Raja, M.R.Raja, Kalaivani / A2 / wife of Dhanakodi, Madhesh @ Raja / A1 S/o.Dhanakodi, Prema / A3 D/o.Dhanakodi and one Juvenile Accused S/o.Dhanakodi belong to the same family.

2.2. Prior to the occurrence, one day the said Dhanakodi came and informed to PW1’s husband / deceased Ramajayam that no one giving food to him and asked to help him. The deceased Ramajayam and the deceased Illayaraja decided to purchase the land belonging to M.R.Raja to an extent of 31 cents for a sum of Rs.2,40,000/- and to that effect, a sale agreement was entered into between M.R.Raja and the deceased / Ramajayam and the agreement was entered into in the name of the deceased Illayaraja and a sum of Rs.1,00,000/- was given as advance sale consideration.

2.3. On 24.06.2010, PW1’s family gone to the said land belongs to M.R.Raja for performing pooja, since the possession of the land was given to PW1’s family on the previous day itself. On that day, PW1, the deceased Ramajayam, deceased Illayaraja, PW6-Tr.Sivalingam, PW2- Tr.Govindaraj, PW3- Tr.Krishnan, PW4-Tr.Mani, PW5- Tr.Sekar went to that agricultural land for performing pooja. When they were performing pooja in the agricultural land, after 15 minutes, accused / A1 to A3 and the Juvenile Accused came there and questioned them, why all of them have gathered there. The deceased Ramajayam replied that they had entered into a sale agreement with M.R.Raja and Rs.1,00,000/- advance was paid for 31 cents and balance sale consideration of Rs.1,40,000/- will be paid afterwards. At that time, all the accused picked up quarrel. PW1’s son stated to A1 that if he has any record, to bring the same and not to disturb. While so, A1 to A3 stated that how dare he can ask evidence from them and stated to stop everything. A2 and A3 instructed A1 to chop him.

2.4. A1 assaulted the deceased Illayaraja on his neck with billhook. Immediately PW1 and the deceased Ramaja

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