George vs State of Tamil Nadu (2024) - Case Analysis

Introduction of George vs State of Tamil Nadu (2024)

The case of George vs State of Tamil Nadu (2024) revolves around the murder of Praveen Kumar which was triggered by a dispute over a Diocese Election. In this case, the Appellant George, Rajarathinam and Albert were accused of killing Praveen Kumar. The conviction was based on the testimony of the father of the deceased Kovilraj (PW-1). The 2-Judge Bench of the Supreme Court examined whether relying on the evidence of an ‘interested witness’ was justifiable and whether the conviction was fair. The Supreme Court on 13th December, 2024 overturned the decision of the Madras High Court and acquitted the Appellant George of all charges.

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Why in the Spotlight? - George vs State of Tamil Nadu (2024)

The 2-Judge Bench of the Supreme Court comprising Justice B. R Gavai and Justice K.V Viswanathan held that the conviction based only on the testimony of Kovilraj (PW-1) was unreliable. The Court acquitted the Appellant George of all charges.

Historical Context and Facts of George vs State of Tamil Nadu (2024)

The case at hand revolves around the murder of Praveen Kumar in connection with a dispute arising from a Diocese Election. The case examines the legal proceedings, evidence presented and the final outcome. The following are the brief facts of the case -

Incident Background

The Appellant George, Rajarathinam and Albert were involved in the murder of Praveen Kumar who was the son of Kovilraj (PW-1) in connection with a dispute arising from a Diocese Election. Kovilraj and along with his family members went to Ananthapuram on 15th May 2015 for a Consecration Festival. 

On 16th May, 2015 midnight Praveen Kumar was standing in front of the Church and was talking to his friends. The three accused individuals approached the deceased Praveen Kumar and verbally abused him over his support for a rival faction in the election. 

The Appellant George after a brief confrontation took out a knife and attacked the deceased Praveen Kumar. The Appellant stabbed him on the left side of his neck. Praveen Kumar, despite attempting to escape, was caught and injured by the Appellant and the two accused Rajarathinam and Albert allegedly held him down.

FIR and Investigation

Kovilraj, the father of the deceased filed a First Information Report (FIR) at the Sathankulam Police Station. The knife used in the attack was recovered based on the confession of the Appellant George. The investigation revealed that the victim was taken to the hospital where he was declared dead.

Charges and Trial

The Trial Court framed charges under Section 294(b), Section 341, Section 302 and Section 506(ii) of the IPC against the Appellant George. The Trial Court convicted the Appellant George and sentenced him to life imprisonment for the murder.

Appeal and High Court Judgment

The Appellant aggrieved by the decision of the Trial Court filed an appeal in the Madras High Court. However, the High Court partly allowed the appeal and upheld the conviction for Section 294(b), Section 341 and Section 302 IPC. The High Court acquitted the Appellant George of the charge under Section 506(ii) IPC. 

Appeal in the Supreme Court

Dissatisfied by the decision of the Madras High Court the Appellant George filed a special leave petition in the Supreme Court. The Appellant challenged the conviction passed by the lower courts.

Issue addressed in George vs State of Tamil Nadu (2024)

The main question which was addressed in this case was whether the conviction of the Appellant George relying on the evidence of an interested witness (Kovilraj) who was also the father of the deceased was justified?

Legal Provisions involved in George vs State of Tamil Nadu (2024)

In George vs State of Tamil Nadu case Section 302 of the Indian Penal Code played a significant role. The following is the legal analysis of this provision -

Section 302 of the Indian Penal Code

Section 302 of the Code provides punishment for murder (Now Section 103 of Bharatiya Nyaya Sanhita 2023). It states that whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.

Judgment and Impact of George vs State of Tamil Nadu (2024)

The 2-Judge Bench of the Supreme Court comprising Justice B. R Gavai and Justice K.V Viswanathan held that the conviction was based only on the testimony of Kovilraj (PW-1) which was found unreliable by the High Court for the other accused. The Court observed that conviction of the Appellant George based on the same testimony when the other accused were acquitted was erroneous. The Court also highlighted that Kovilraj (PW-1) who was the father of the deceased was an interested witness and should have been scrutinized more carefully. The Supreme Court overturned the judgment of the Madras High Court and acquitted the Appellant George of all charges. Thus, the Supreme Court allowed the appeal and highlighted errors in the decision of the High Court of Madras of the evidence and the unjust conviction of the Appellant based on uncertain testimony.

Conclusion

In George vs State of Tamil Nadu (2024) the Supreme Court allowed the appeal and acquitted the Appellant George of all charges. The Court highlighted the errors in the decision of the High Court of Madras of the evidence and the unjust conviction of the Appellant based on uncertain testimony.