MANOHARAN VS. STATE BY INSPECTOR OF POLICE

Author: Priscilla B, B. S. Abdur Rahman Crescent Institute Of Science And Technology

INTRODUCTION

This case proves to be one of the heinous crimes in the Indian criminal jurisprudence. It involves abduction, sexual assault and murder which is brutal of two minor children in coimbatore, Tamil Nadu.

The appellant of this case, Manoharan and his co-accused were charged with multiple offences under the then Indian Penal Code, 1860 which is presently known as the Bharatiya Nyay Sanhitha, 2023. The offences involved rape and muder . The case had a chilling sequence of events which shocked the entire nation.

This case ascended to the supreme court, where the main legal questions were around the voluntariness and admissibility of the accused’s confessions and whether the circumstances justified the imposition of the death penalty under the rarest of rare doctrine established in bachan singh vs. state of punjab.

The judgment of the case reaffirmed the gravity of sentencing in cases of extreme brutality and also gave a significant discourse on the application of capital punishment in this modern era.

FACTS OF THE CASE

One of the accused Mohanakrishnan borrowed a car without taking the consent of the owner and kidnapped two children outside the temple when they were leaving for school.
The two children who were kidnapped included a boy and a girl aged seven and ten respectively.
Kidnapper took the children to the petrol pump in the car and picked up the appellant from his house in Angalakurichi.
The children were taken to a remote location, referred to as Gopalsamy Temple Hills, and point rape was allegedly committed on the girl whose hands were tied by both Mohanakrishnan and the appellant.
Attempts were made to kill the children by feeding them cow dung mixed with milk which was poisonous to get rid of them. But this attempt failed and the children didn’t die as they consumed only a small portion.
Then the accused threw the children into the Parambikulam-Aliyar Project Canal and fled away.
School Bags were seen floating on the canal. One of the accused Mohankrishnan was caught by the police on the same evening of the day with the help of information provided.
The next day the body of the girl was recovered from that canal. After a few days the appellant was also arrested and the body of the boy was also recovered.
Mohanakrishnan was later shot dead in an encounter by the police.

LEGAL ISSUES

Whether confession made by the appellant was voluntary and legally admissible

This is one of the core issues before the court. Manoharan, the appellant partially retracted his confession while admitting to being present but denying any direct involvement in the assault and murder. The court had to evaluate whether the confession made by him was without any coercion and whether it can be relied upon as valid evidence.

This issue proves to be crucial because confession plays an important role in the case of criminal trials. If the confession is a forced or manipulated one, it can lead to a misadministration of justice but if it is a genuine confession, it is said to be one of the key pieces of evidence. It can also be viewed that this case tested the protection under the criminal law of the country which is under Section 24-27 as viewed under the then Indian Evidence Act which deals with the admissibility of confessions.

Whether the case falls under the “rarest of rare” category ?

The court had to assess if the circumstances of the crime were so brutal and exceptional that capital punishment was the only justifying sentence. This implied applying the doctrine which was first established in the case of Bachan Singh v. State of Punjab.

This issue has a broader societal and constitutional implication. Capital punishment is irreversible and its imposition wants the highest standards of judicial scrutiny. This case also forced the court to consider whether the brutality of the crime outweighed the chance of reform and rehabilitation.

COURT’S DECISION

The case was brought before the supreme court which involved the bench consisting of Justices Rohinton Fali Nariman, Sanjiv Khanna and Surya Kant. it didn't take them long to notice the absolute brutality involved. The court upheld the appellant’s conviction firmly concluding that this was a crime that came under the category of “rarest of rare” . This didn't leave room for leniency.

To reach the decision, the court carefully viewed the evidence, especially Manoharan's own confession. even though he tried to backtrack it and claimed he was only present during the crime and did not participate. The court found that his confession was made voluntarily and the details matched with the independent evidence collected during the investigation. It was also proved that there was no sign of coercion or undue pressure. This provided the bench with confidence that his confession could be trusted and taken into account as evidence which they could rely on while giving their judgement.

Moving on to the punishment, the court took into account the principles laid down in the case of Bachan Singh v. State of Punjab, which states that death penalty must be awarded only when the crime committed is monstrous and the criminal is said to be beyond redemption and that nothing less would be able to serve justice. Here, the bench observed that the crime didn't just fall into the category of cruelty but was carefully planned and executed against very innocent, defenseless children and was a shocking indifference to human life.

There was a slight split among the judges. Justice Sanjiv Khanna felt that even though the crime committed was undeniably horrific, the “rarest of rare” test requires separate factors. He was a bit more hesitant about imposing capital punishment (i.e) the death penalty. The majority consisting of justices Rohinton Fali Nariman and Surya Kant believed that the committed offence was a cold-blooded one, devoiding humanity depriving them of mercy. It also emphasised that such a crime has a deep impact on society’s conscience which cannot be ignored.

Finally, it was held that, in cases where the crime seems to shake the collective conscience of society, the law must respond with its most difficult punishment. This reaffirms that the majority confirmed the appellant’s death sentence.

IMPACT OF THE CASE

The judgement didn't just give a conclusion and close the case but also sent out a strong, undeniable message about the Indian legal system which views the crime of extreme brutality, especially those against children.

By confirming the death penalty, the supreme court reinforced the “rarest of rare” doctrine which is not just a theoretical idea but also a living principle that the courts are willing to apply when an offence is said to be crossing an imaginable limits of cruelty. This also showed that the courts were prepared to act strongly when the crime doesn't just harm individuals but wounds the soul of the society.

In the viewpoint of the society, the judgement gave assurance that people are often in fear that the justice is slow or uncertain which reflects the court’s sensitivity towards the victims. It also showed that in cases where human dignity is trampled , the law steps up to protect the collective moral standards of the community.

The slight difference of opinion among the bench reminded people that the death penalty debate is still complex in india. Justice Khanna’s cautious approach gave out the statement that even in the most horrific cases, courts have to take into account every factor carefully before taking an irreversible step. His view is said to have kept alive the conversation about whether the death penalty as a practice can ever be perfectly fair.

It can be said that this case became a significant marker in the criminal law of india. It is not just because of horrific facts but also for the way it tested and confirmed the principles which govern life and death decisions under the constitution of india.

PERSONAL ANALYSIS

When I take a look at the judgement of this case, it is hard not to agree with the court’s decision. The brutality of the acts which involve the kidnappng, the sexual assault, the calculated poisoning attempt and ultimately the cold-blooded drowning of the two innocent children, all let a very little space for mercy. This wasn’t just a crime against the two innocent children but also against humanity itself.

One of the strengths of the court’s reasoning is in its careful examination of the evidence. Rather than rushing to a conclusion, the judges took their time to check the evidence whether they were gathered voluntarily and corroborated by independent facts. That step was crucial in regards to confessions, as they are often considered a tricky territory. The court’s cautious approach gave weight and legitimacy to the final outcome.

Another important point was the reaffirmation of the “rarest of rare” test. The majority’s view that some crimes are so deeply shocking that society’s collective conscience needs the highest punishment gives the core idea of justice. In cases like this, the death penalty isn't just about retribution, it's about sending a message that certain lines, once crossed, leave no room for redemption.

If i had to point out one weakness, it would be that the judgement can engage a little more deeply with the idea of possible reform or mental state of the accused. Even though the facts here made redemption seem highly unlikely, a structured analysis of the mitigating circumstances would have made the judgement even more robust and future-proof.

On the whole, I believe that the court struck the right balance between compassion for the victim and adherence to the rule of law. This case stood as a grim but necessary reminder that justice must sometimes be unflinchingly firm to uphold the moral fabric of society.

CONCLUSION

This case stood as a powerful example of how the Indian judiciary grapples with the most difficult and heartbreaking cases. By carefully examining the evidence, applying the doctrine of “rarest of rare” which balances the competing principles of justice and humanity. The court delivered a judgement that strongly resonated with the society's need for accountability and closure. While slight disagreement among the judges shows the ongoing complexities around capital punishment , the majority decision shows that when a crime which crosses all limits of cruelty is committed, the law will respond with utmost seriousness. In my view, a system that must remain compassionate yet unafraid to act firmly when justice demands it.