KP Tamilmaran vs State Rep by Deputy Superintendent of Police: Honor Killing

KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 case drew attention due to the gruesome nature of the offence which involved the caste-based honour killing of an inter-caste couple, Kannagi and Murugesan, in Tamil Nadu. The case gained prominence not only because of the heinous murder arranged by the family of the victim but also due to the involvement of police officers in suppressing justice. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 Introduction

The landmark judgement KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 revolves around the brutal honour killing of an inter-caste couple, Kannagi, a member of the Vanniyar community, and Murugesan, a Dalit. The couple’s secret marriage in 2003 led to the couple’s tragic murder by Kannagi’s family. The case gained significance due to the involvement of police officers, who delayed the registration of an FIR and fabricated evidence to protect the perpetrators. The case brought to light serious concerns about caste-based atrocities, police misconduct and the judicial handling of caste-sensitive cases.

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The case at hand centres around the honour killing of an inter-caste couple, Kannagi and Murugesan, in Tamil Nadu in 2003. The brutal murder was planned by the family of the woman due to caste prejudice, as Kannagi belonged to the Vanniyar community and Murugesan, a Dalit, had secretly married her. The case gained attention not only for the grievous nature of the offence but also for the active role of police officers in suppressing justice which led to their conviction alongside the main accused. The following are the facts of KP Tamilmaran vs State Rep by Deputy Superintendent of Police -

Facts of the Case: The Double Murder

The KP Tamilmaran vs State Rep by Deputy Superintendent of Police case concerns the heinous caste-based murder of a young couple, Murugesan and Kannagi, who were poisoned to death in front of villagers. Kannagi’s father and brother committed the offence, angered by her inter-caste marriage to Murugesan, a Dalit. The act is labelled as an 'honour killing' which was driven by caste prejudice.

The Relationship and Elopement

Murugesan and Kannagi, from Pudukoorapettai village, Cuddalore, were in a relationship. Murugesan, a chemical engineering graduate, worked in Bangalore; Kannagi was pursuing a B.Com degree. They were aware of the opposition they would face; they married secretly on 5th May, 2003 before the Cuddalore Marriage Registrar and continued living with their families until early July 2003, when they eloped.

Events Leading to the Murder

On 3rd July, 2003, A-2 went to Murugesan’s father’s house (PW-1) with a sickle and demanded Murugesan's return. PW-1 later located Murugesan and persuaded him to send Kannagi back. On 7th July, 2003, A-2 again threatened PW-1. On 8th July, 2003, PW-1 returned home to discover the couple had been murdered.

Brutal Torture and Administration of Poison

According to the Prosecution:

• Murugesan’s uncle, A-4, brought him back to the village under pressure from A-2.
• Upon return, Murugesan was tied to a post and brutally beaten by A-1 to A-13, in public.
• Under duress, he revealed Kannagi’s location. A group including A-4 to A-11, retrieved her.
• In a cashew grove, A-1 handed Nuvacron (a toxic insecticide) to A-2, who forced Kannagi to drink it, and killed her.
• A-2 also attempted to poison Murugesan. PW-49 (Murugesan’s stepmother) testified that A-2 poisoned him, contradicting claims that A-4 was responsible. The testimony led to the acquittal of A-4.
• PW-49’s testimony was admitted through Section 311 of Criminal Procedure Code as she was not mentioned as a witness in the charge sheet.

Police Complicity and Suppression of Evidence

A-14 and A-15, the police officers, were complicit:

• They were present at the scene on 8th July, 2003 but failed to register an FIR which violated Section 154 and Section 157 CrPC.
• When PW-49 attempted to file an FIR the same day, she was abused and turned away.
• It was only after public agitation and media attention led by Dalit leaders that a First Information Report was registered on 17th July, 2003.
• The FIR was based on an extra-judicial confession by A-1 to PW-32 (Village Administrative Officer).

Trial Court Proceedings and Convictions

A total of fifteen accused stood trial. The Trial Court convicted thirteen of them. The Trial Court notably:

• A-1 to A-3, A-5 to A-8, and A-10 to A-13 were convicted under Section 302 r/w Section 149 of Indian Penal Code and sentenced to life imprisonment, except A-2 (Maruthupandiyan), who was awarded the death penalty.
• A-14 and A-15, both police officers, were convicted under Section 217 and Section 218 IPC and Section 3(2)(i) and Section 4 of the SC/ST Act and were sentenced to life imprisonment.
• A-4 (Ayyasamy) and A-9 (Gunasekaran) were acquitted and no appeal was filed against their acquittal.

Madras High Court Modifications

The Madras High Court, in its 8th June, 2022 judgment:

• Acquitted A-14 (Sub-Inspector K.P. Tamilmaran) under Section 3(2)(i) of the SC/ST Act and Section 218 IPC but upheld his conviction under Section 4 of the SC/ST Act and Section 217 IPC and reduced his sentence to two years of rigorous imprisonment.
• Upheld the conviction of A-15 (Inspector M. Sellamuthu) with no sentence reduction.
• Reduced A-2’s sentence from death to life imprisonment.
• Acquitted A-3 (Rangasamy) and A-13 (Chinnadurai).
• Dismissed the appeals of the other accused and upheld their convictions.

No appeal was filed against the acquittals of A-3 and A-13. The present appeals are by A-1, A-2, A-5 to A-8, A-10 to A-12, A-14, and A-15.

Challenge Before the Supreme Court

Dissatisfied by the decisions of the Madras High Court, the aggrieved approached the Apex Court. The appeals before the Supreme Court challenged the judgment of the Madras High Court dated 8th June, 2022.

KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 Legal Issues

The following issues were also addressed in KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025:

• Honour Killing:
  The main issue in this case was whether the murder of Kannagi and Murugesan, committed by the woman’s family members, constituted an instance of honour killing punishable under Sections 302 and other related provisions of the Indian Penal Code.
• Caste-Based Discrimination and Atrocities:
  The Supreme Court examined whether the actions of the accused including police officers, fell under the ambit of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act especially Section 3(2)(i) and Section 4 which deal with atrocities against Dalits and dereliction of duty by public servants.
• Police Misconduct and Fabrication of Evidence:
  The Apex Court in KP Tamilmaran vs State Rep by Deputy Superintendent of Police analysed whether the police officers, by failing to register the First Information Report promptly, using caste-based abuses and falsely implicating innocent Dalits, were guilty of offences under Sections 217 and Section 218 of the IPC.
• Delay in Registration of FIR:
  Lastly, the Court also determined whether the delay in registering the FIR infringed Section 154 of the CrPC and the principles laid down in Lalita Kumari v. State of Uttar Pradesh which mandates immediate registration of FIRs in cognizable offences.

The Supreme Court in KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025. addressed multiple legal provisions under the Indian Penal Code (IPC), Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 and Code of Criminal Procedure (CrPC). The following are the analysis of these provision:

• Section 302 IPC: Punishment for Murder

According to Section 302 (Now Section 103 of Bharatiya Nyaya Sanhita, 2023) anyone who commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.
In KP Tamilmaran vs State Rep by Deputy Superintendent of Police, the main accused were found guilty of the honour killing of the inter-caste couple and were convicted accordingly under this section.

• Section 217 IPC: Public servant disobeying direction of law with intent to save person from punishment

Section 217 (Now Section 255 of Bharatiya Nyaya Sanhita, 2023) is applicable to:

1. A person is a public servant (e.g., a police officer)
2. The law requires them to act in a certain way (e.g., register an FIR when informed of a crime)
3. But they knowingly disobey that legal requirement
4. And do so to protect someone from criminal punishment or to protect property from lawful seizure.
   Anyone who is guilty under Section 217 IPC is liable to be punished up to 2 years’ imprisonment or fine or both.

This provision was invoked against Sub-Inspector K.P. Tamilmaran and Inspector M. Sellamuthu for deliberately failing to register the FIR and shielding the real culprits in KP Tamilmaran vs State Rep by Deputy Superintendent of Police.

• Section 218 IPC: Public servant framing incorrect record or writing with intent to save person from punishment

Section 218 (Now Section 256 of Bharatiya Nyaya Sanhita, 2023) punishes a public servant who is responsible for preparing official records or documents and intentionally prepares them falsely, knowing they are incorrect. If this is done with the intent to protect someone from punishment or protect property from legal seizure, or to cause harm or loss, the public servant can be punished with up to imprisonment for three years or with fine, or both. 

This section was specifically against Sellamuthu, who fabricated extra-judicial confessions and falsely implicated Dalit victims in KP Tamilmaran vs State Rep by Deputy Superintendent of Police.

• Section 3(2)(i) of Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

Section 3(2)(i) of the Act punishes a public servant who knowingly files a false charge against a member of a Scheduled Caste or Scheduled Tribe leading to a capital offence. This section was invoked in this case as false evidence was deliberately created to falsely charge Dalit persons.

• Section 4 Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

Section 4 of the Act punishes public servants who wilfully neglect their duties required under the Act. In KP Tamilmaran vs State Rep by Deputy Superintendent of Police this section was applied as the officers failed in their statutory duties including registering FIRs and conducting a fair investigation in caste atrocity cases.

• Section 154 of Criminal Procedure Code: Information in cognizable cases

Section 154 (Now Section 173 of Bharatiya Nagarik Suraksha Sanhita, 2023) mandates immediate registration of FIR upon receiving information of a cognizable offence. The failure of the Police to comply constituted a violation.

KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 Judgment and Impact

On 28th April, 2025, the Supreme Court of India in KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 upheld the convictions of nine individuals involved in the heinous caste-based murder of the inter-caste couple. The Bench comprising Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra dismissed all appeals which challenged the decision of the Madras High Court decision dated 8th June, 2022.

Conviction of Police Officers

The Supreme Court affirmed the convictions of two police officers, K.P. Tamilmaran (Sub-Inspector) and M. Sellamuthu (Inspector) who were found guilty of misconduct, dereliction of duty and fabricating evidence to shield the actual perpetrators and falsely implicate members of the Dalit community:

• K.P. Tamilmaran (A-14) was convicted under Section 217 IPC and Section 4 of the SC/ST (Prevention of Atrocities) Act. His sentence was reduced by the High Court to two years of rigorous imprisonment which the Supreme Court upheld.
• M. Sellamuthu (A-15) was convicted under Sections 217 and 218 IPC and Sections 3(2)(i) and 4 of the SC/ST Act. His life sentence was also upheld by the Supreme Court and recognized him as the principal conspirator behind the fabrication of the FIR and the malicious prosecution of innocent Dalit individuals.

The Supreme Court in KP Tamilmaran vs State Rep by Deputy Superintendent of Police criticized both officers for delaying the registration of the FIR, using caste-based abuse and deliberately manipulating the investigation to protect the accused from the Vanniyar community. The decision invoked the principles established in Lalita Kumari v. Govt. of UP, emphasizing the mandatory registration of FIRs upon receiving information about a cognizable offence.

Observations on Police Misconduct

The Supreme Court categorically stated that A-15 (Sellamuthu) was responsible for arranging a false narrative through manufactured extra-judicial confessions. He knowingly implicated four Dalits in a capital offence to divert attention from the real perpetrators who were members of the Vanniyar community. The Supreme Court in KP Tamilmaran vs State Rep by Deputy Superintendent of Police upheld both the findings of the Trial Court and the High Court and affirmed that Sellamuthu was guilty beyond doubt.

Confirmation of Life Sentences for Other Accused

The Supreme Court in KP Tamilmaran vs State Rep by Deputy Superintendent of Police upheld the life sentences of nine other accused including Kannagi’s father and brother, who played primary roles in the honour killing. These individuals were mainly convicted under Section 302 r/w Section 149 IPC and their participation in the murder was found to be proven beyond reasonable doubt.

Conclusion

The landmark judgement KP Tamilmaran vs State Rep by Deputy Superintendent of Police 2025 the Supreme Court on 28th April, 2025 upheld the convictions of both the main accused and the police officers involved. The case reinforced the importance of immediate action in cases of cognizable offences and highlighted the important role of the judiciary in safeguarding the rights of marginalized communities.