In a significant judgment, the Supreme Court of India commuted the death sentence of Ramesh A. Naika, convicted for the brutal murder of his two minor children, to life imprisonment without the possibility of remission. The bench, comprising Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta, upheld his conviction but modified the sentence imposed by the lower courts.
Background of the Case
Ramesh A. Naika, a former bank manager, was convicted of the heinous murder of his 10-year-old son Bhuvanraj and 3.5-year-old daughter Krithika in June 2010. The case, which shocked the nation, was rooted in a family dispute over Naika’s disapproval of his sister-in-law’s relationship. The prosecution argued that Naika, enraged by his wife and sister-in-law’s refusal to comply with his wishes, planned and executed the murders as an act of revenge.
According to the prosecution, Naika first murdered his sister-in-law, Savitha, and mother-in-law, Saraswathi, in Tumkur before traveling to Mangalore, where he took his two children on a drive under the pretense of an outing. He then drowned them in a water tank located in the gardens of a known acquaintance. Following the crime, he sent a message to his wife urging her to commit suicide. When she informed her family instead, the matter was reported to the police, leading to Naika’s arrest.
Legal Proceedings and Issues
The trial court, based on circumstantial evidence, found Naika guilty under Section 302 of the Indian Penal Code (IPC) and sentenced him to death. The Karnataka High Court upheld the conviction and confirmed the death sentence, concluding that the crime fell under the ‘rarest of rare’ category.
Key legal issues in the case included:
Circumstantial Evidence – The prosecution relied on indirect evidence, including witness testimonies, forensic reports, and call records to establish Naika’s guilt.
Motive – The court determined that Naika was enraged by his sister-in-law’s defiance and intended to punish his wife and her family by killing their children.
Admissibility of Electronic Evidence – The defense challenged the SMS messages presented as evidence, citing non-compliance with Section 65B of the Indian Evidence Act. However, the court ruled that they were corroborative in nature and admissible.
Death Penalty vs. Life Imprisonment – The Supreme Court re-evaluated whether the case met the criteria for the death penalty under the ‘rarest of rare’ doctrine.
Supreme Court’s Ruling
While upholding Naika’s conviction, the Supreme Court ruled that the death sentence was not warranted due to the following mitigating factors:
Naika had no prior criminal record.
His good behavior and positive relations with family members were noted.
His conduct in custody did not indicate that he was beyond reformation.
The case was based on circumstantial evidence rather than direct proof.
The Supreme Court observed: “The absolute irrevocability of the death penalty renders it completely incompatible with the slightest hesitation on the part of the court.”
The bench further stated that the possibility of reformation must be considered before imposing the death penalty. Citing precedents where the Supreme Court commuted death sentences in cases based on circumstantial evidence, the judges concluded that Naika should serve a life sentence without the possibility of remission.
