Renukaswamy Murder Case: Bengaluru Court Directs Approver Pradosh Rao's Examination Next Week

The LVIII Additional City Civil and Sessions Court in Bengaluru on Friday directed that accused-turned-approver Pradosh S. Rao be examined as a prosecution witness on September 2, 2026, in the high-profile Renukaswamy murder case. The order came after a hearing where actor Darshan (accused No. 2) requested an adjournment to pursue an appeal against the conditional pardon granted to Rao, while the Special Public Prosecutor (SPP) pressed for an earlier date. The court, balancing the competing submissions, set the examination for next week, noting that Rao would be physically produced before the court on that date.

Background of the Renukaswamy Murder Case

The case involves the murder of Renukaswamy, a 33-year-old man from Chitradurga, whose body was discovered in a drain near Kamakshipalya in Bengaluru in June 2024. The investigation led to the arrest of Kannada actor Darshan, along with several others, including Pradosh S. Rao. Darshan, a prominent figure in the Kannada film industry, has been in judicial custody since his arrest. The trial is being conducted under the supervision of the LVIII Additional City Civil and Sessions Court, with the case registered as SC 1319/2024 (Kamakshipalya P.S. v. Pavithra Gowda & Ors.).

On August 25, 2024, the trial court granted Rao a conditional pardon under Section 306 of the Code of Criminal Procedure (CrPC), converting him from accused No. 14 to an approver. Rao subsequently read the pardon order and accepted its terms, stating his readiness to testify honestly and fully. The development triggered legal challenges from co-accused Darshan, who sought to file objections to the pardon application. However, the trial court earlier ruled that at the stage of considering an approver application, only the accused seeking pardon, the prosecution, and the court are concerned—the other co-accused have no right to participate.

Court Overrules Objections, Sets Date for Approver Testimony

During Friday's proceedings, the SPP urged the court to examine Rao as a witness on August 31, citing the need to confront him with documents and material objects. The SPP further requested Rao's physical presence in court, emphasizing the evidentiary value of his testimony. However, Darshan's counsel submitted that the actor intended to prefer an appeal against the order granting pardon to Rao, and therefore sought an adjournment until the following Wednesday (September 2).

The court, presided over by Judge S.M. Sambrani, recorded the submissions in its order: “Considering the submission of the learned SPP and counsel for A2, Accused No.14 is treated as witness of the prosecution. Hence, Mr. Pradosh S. Rao shall be examined as prosecution on 02.09.2026.” The court further directed issuance of witness summons to Rao and ordered intimation to the Jail Authorities and the Police Inspector of Kamakshipalya Police Station to ensure his physical production on the scheduled date.

The order notably accommodates Darshan's request for a short adjournment, allowing him time to file the appeal while balancing the prosecution's need to proceed with the approver's examination.

Legal Framework Governing Approvers

The appointment of an approver is governed by Sections 306 and 307 of the CrPC, which allow a court to tender a pardon to an accomplice in exchange for a full and truthful disclosure of the facts surrounding the offense. Once the pardon is accepted, the approver becomes a witness for the prosecution, and their testimony can be used as substantive evidence against the other accused. However, the evidence of an approver is always viewed with caution and requires corroboration in material particulars, as established by the Supreme Court in Suresh Chandra Bahri v. State of Bihar (1995) and R. v. Baskerville (1916).

The Karnataka High Court, in its judgment dated August 13, 2024, had dismissed Darshan's petition challenging the trial court's refusal to allow him to file objections to Rao's approver application. The High Court upheld the trial court's view that co-accused have no standing at the stage of consideration of a pardon application, a position consistent with the principle that the decision to grant pardon lies within the discretion of the prosecution and the court, subject to the condition that the approver's evidence is not the sole basis for conviction.

Implications for the Trial and Co-Accused

The examination of Pradosh Rao as a prosecution witness marks a critical phase in the trial. As an insider to the events, Rao's testimony could provide direct evidence regarding the planning and execution of the murder, potentially implicating Darshan and other accused. The prosecution is expected to use Rao's statement to build a corroborated chain of circumstantial evidence.

For Darshan, the challenge lies in undermining Rao's credibility and demonstrating that the pardon was granted under questionable circumstances. Darshan's counsel has indicated that the appeal against the pardon order will be based on arguments that the trial court erred in not hearing the co-accused and that Rao's testimony may be unreliable. However, the High Court's earlier rejection of similar objections limits the scope of this challenge.

Legal Community's Perspective

Legal practitioners are closely watching this case, as it raises important questions about the rights of co-accused in the pardon process. The prevailing jurisprudence emphasizes that the grant of pardon is a matter between the prosecution and the accused seeking it, with the court acting as a guardian to ensure the pardon is not used oppressively. Yet, the exclusion of co-accused has been criticized by some as undermining the principles of natural justice, particularly when the approver's testimony can be pivotal.

The case also highlights the logistical challenges of ensuring the physical production of an approver who may face threats or pressure from the co-accused. Rao's counsel had earlier submitted that his client was under "severe pressure," and the court's direction for his physical presence is intended to secure a free and voluntary statement.

Looking Ahead

With the examination scheduled for September 2, 2026, all eyes are on the LVIII Additional City Civil and Sessions Court. The proceeding will likely set the tone for the remainder of the trial. If Rao's testimony holds up under cross-examination and is corroborated by other evidence, it could significantly strengthen the prosecution's case against Darshan and the other accused.

Meanwhile, Darshan's legal team will use the intervening period to prepare the appeal against the pardon order, hoping to either delay the trial or have Rao's approver status revoked. The Karnataka High Court's response to this appeal will be crucial in shaping the trajectory of the case.

In a broader context, the Renukaswamy murder case has already captured public attention due to the celebrity status of the main accused. The legal developments underscore the delicate balance between securing convictions through approver testimony and safeguarding the rights of all accused—a balance that Indian courts continue to navigate with careful procedural steps.