16 July 2025 Legal Updates

'FAULTY INVESTIGATION' : SUPREME COURT ACQUITS MAN ON DEATH ROW, ISSUES NATIONWIDE GUIDELINES ON DNA EVIDENCE HANDLING

(a) Case Title:

• Kattavellai @ Devakar v. State of Tamil Nadu

(b) Court:

• Supreme Court of India

(c) Date of Decision: 

• 15th July 2025

(d) Bench:

• Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta

Key Facts:

Two victims, Ezhil Muthalvan and Kasturi, were brutally murdered and Kasturi was raped in Suruli Falls, Tamil Nadu, on 14th May 2011. The prosecution alleged the accused, Kattavellai @ Devakar, committed the crimes due to robbery and caste-based motives.

Trial & Conviction:

The Trial Court and High Court convicted the accused under Sections 302 (murder), 376 (rape), and 397 (robbery) IPC, sentencing him to death. The case relied on circumstantial evidence, including last-seen theory, DNA evidence, and recovery of stolen articles.

To ensure the integrity of DNA evidence in criminal investigations, the Supreme Court laid down the following mandatory guidelines:

1. Documentation During Collection

DNA samples must be collected with proper labelling, including: FIR number and date, Relevant legal sections, Details of the Investigating Officer (IO) and police station, Unique serial number. The collection record must bear signatures of Medical professional, Investigating Officer, Independent witnesses (if available).

Note: Absence of independent witnesses must be recorded with reasons.

2. Timely Transportation to Forensic Labs

The Investigating Officer (IO) is responsible for ensuring samples reach the Forensic Science Laboratory (FSL) within 48 hours of collection. If delayed, the reason must be documented in the case diary.

3. Storage and Handling

No tampering: DNA packages cannot be opened, altered, or resealed without:

• Court’s permission (based on a medical expert’s justification).
• Preservation: Samples must be stored in pristine conditions (temperature-controlled if necessary).

4. Chain of Custody Register

A mandatory register must track every movement of DNA evidence from collection → police station → FSL → court.

Each transfer must be countersigned with timestamps and reasons. The register must be part of the trial record. Non-compliance: IO must explain lapses; failure may weaken prosecution.

5. Compliance by Police Authorities

State DGPs must:

• Design standardized forms for Chain of Custody.
• Train Investigating Officers on these protocols.

Why These Guidelines?

• Prevent contamination/tampering of DNA evidence (a recurring issue in cases like Manoj v. State of M.P., 2023).
• Ensure admissibility in court (gaps in custody often lead to acquittals).
• Uphold Article 21 (right to fair trial) by reducing wrongful convictions.

Final Judgment:

• Acquittal: The Supreme Court set aside the conviction, ruling the prosecution failed to prove guilt beyond reasonable doubt.
• Compensation Suggestion: The Court highlighted the need for legislative measures to compensate wrongfully incarcerated individuals (referring to Article 21 rights).

'STATE MUST UPHOLD RIGHTS OF PRISONERS WITH DISABILITIES': SUPREME COURT ISSUES DIRECTIONS FOR PRISONS IN TAMIL NADU

(a) Case Title:

• L. Muruganantham v. State of Tamil Nadu & Others

(b) Court:

• Supreme Court of India

(c) Date of Decision:

• July 15, 2025

(d) Bench:

• Justices J.B. Pardiwala and R. Mahadevan

Key Facts:

The appellant, L. Muruganantham, an advocate with 80% locomotor disability (Becker Muscular Dystrophy) and autism, was falsely implicated in a criminal case and arrested in 2020. During his 10-day incarceration, he alleged denial of medical care (physiotherapy, psychotherapy), protein-rich diet, and accessible prison facilities, violating the Rights of Persons with Disabilities Act, 2016 (RPwD Act) and Article 21 (right to dignity).

The State Human Rights Commission (SHRC) awarded ₹1 lakh compensation, later enhanced to ₹5 lakh by the Madras High Court. The appellant sought further compensation and systemic reforms for disabled prisoners.

Supreme Court’s Observations:

1. Compensation:

• Upheld the High Court’s enhancement to ₹5 lakh, noting the appellant’s suffering but found no deliberate neglect by prison authorities.
• Non-provision of luxury items (e.g., specific protein-rich food) doesn’t violate fundamental rights unless it causes demonstrable harm.

2. Prison Reforms for Disabled Persons:

• Highlighted systemic neglect of disabled prisoners, citing outdated prison manuals and lack of accessibility (ramps, toilets, healthcare).

Directions Issued:

• Accessibility: Prisons must conduct audits, provide wheelchairs, sensory-safe spaces, and accessible toilets.
• Healthcare: Ensure physiotherapy, psychotherapy, and assistive devices.
• Training: Sensitize prison staff on disability rights.
• Data Transparency: Maintain records of disabled prisoners and publish compliance reports.
• Legal Reforms: Amend prison manuals to align with the RPwD Act and international standards.