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Supreme Court on Witnesses Related to Victim

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🏛️ Latest 2025 Supreme Court Judgment on Witnesses Related to the Victim

Delhi Law Academy Jaipur presents below a summarized version of the latest Supreme Court Judgment on “Witnesses Related to the Victim” in the case of K. P. Tamilmaran v. State, delivered by a two-judge Bench comprising Sudhanshu Dhulia and Prashant Kumar Mishra JJ on 28 April, 2025, for aspirants of RJS, DJS, PCS(J) and other Judicial Services throughout India.


⚖️ K. P. Tamilmaran v. State – JUDGMENT

📌 Facts of the Case

This is a case of a dastardly murder of a young couple, Murugesan and Kannagi, who were in their early twenties when they were killed. Both were administered poison in full view of villagers.

👉 The masterminds were none other than Kannagi’s father and brother, angered by her marriage to Murugesan, a Dalit, while she belonged to the Vanniyar community.
👉 The crime is a brutal case of so-called honour killing.
👉 The incident occurred on 7th–8th July 2003, but the trial concluded only in September 2021.

This delay in justice highlights inefficiency in prosecution and dilatory defence tactics.

Another crucial aspect is that many prosecution witnesses turned hostile, and the defence argued that testimonies relied mainly on Murugesan’s relatives, who were “interested witnesses.”


📖 The Law on Witnesses Related to the Victim

The defence contended that several witnesses (PW-49, PW-1, PW-15) were related to the victim.

👉 But the settled law is:
A witness’s testimony cannot be discarded merely because they are related to the victim. Courts must scrutinize with caution but can rely on credible related witnesses.


📚 Precedents

📜 Precedent 1: Jaikam Khan v. State of U.P. (2021)

“Merely because the witnesses are related, it cannot be a ground to disbelieve them. If credible, courts can rely on their testimony.”

Close relatives are often natural witnesses, especially when crimes occur near the residence of the deceased.

📜 Precedent 2: State of A.P. v. S. Rayappa (2006)

The Court distinguished between:

  • Interested witness = someone with motive to falsely implicate.

  • Related witness = natural witness, not inherently biased.

It noted that close relatives usually seek justice against the real culprit and shouldn’t be disbelieved automatically.


✅ Conclusion

Related witnesses are not necessarily interested witnesses. Courts can rely on their testimony if it inspires confidence.


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