Introduction:

The Karnataka High Court, while deciding Criminal Appeal No. 69 of 2018, filed by Rudresh @ Rudraiah against the State of Karnataka, delivered an important ruling clarifying the limits of sentencing powers of Sessions Courts in cases involving life imprisonment, even while affirming the conviction for the brutal murder of a 3½-year-old child, the Division Bench comprising Justice H.P. Sandesh and Justice Venkatesh Naik T examined whether a trial court could legally sentence a convict to imprisonment for life “till his natural death” and thereby deny the statutory possibility of remission, and while the Court found no infirmity in the finding of guilt under Section 302 of the Indian Penal Code based on strong circumstantial evidence including motive, preparation, recovery, and scientific proof, it held that the Sessions Court had exceeded its jurisdiction by prescribing life imprisonment without remission, a power that, as per settled constitutional jurisprudence and reaffirmed by the Supreme Court in Kiran v. State of Karnataka (2025), lies exclusively with Constitutional Courts, namely the High Courts and the Supreme Court, particularly when such punishment is imposed as an alternative to the death penalty, the case arose from a deeply disturbing incident where the prosecution alleged that the accused, who used to work and loiter in a Mutt (Hindu monastic institution), harboured intense resentment against the mother, grandmother, and great-grandmother of the deceased child due to repeated scolding and accusations of theft and misconduct, and out of this hostility, he allegedly kidnapped and murdered the child after administering a sleeping tablet, later leading the police to the recovery of the dead body and the remaining tablets, the Sessions Court had convicted the accused for murder and sentenced him to life imprisonment till natural death, thereby excluding remission and set-off benefits, which led the accused to challenge both the conviction and the sentence before the High Court, contending that the prosecution case was unreliable and that the sentence was legally unsustainable, while the State argued that the crime was heinous, fully proved, and deserving of the harshest punishment permissible in law, setting the stage for the High Court to examine both the evidentiary foundation of guilt and the legality of the sentence imposed.

Arguments:

On behalf of the appellant Rudresh @ Rudraiah, it was contended that the entire case of the prosecution was based on circumstantial evidence which did not form a complete chain pointing unerringly towards guilt, and it was argued that there were gaps in the prosecution story relating to motive, last-seen theory, recovery, and medical correlation, the defence submitted that mere allegations of prior disputes or scolding by the complainant could not automatically translate into a strong motive for committing such a heinous offence, and that witnesses from the Mutt had painted the accused as a person of bad character only to prejudice the Court, it was further argued that the alleged purchase of sleeping tablets was not conclusively connected to the administration of poison or sedative to the child, and that recovery of tablets was planted or at least doubtful, the defence also questioned the credibility of witnesses who were either closely connected to the complainant or associated with the Mutt, and thus interested witnesses, and submitted that the prosecution had failed to establish the exact sequence of events leading to the death, the time of death, and the exclusive opportunity of the accused to commit the crime, it was further argued that even assuming guilt, the Sessions Court acted illegally in sentencing the accused to imprisonment for life till natural death, as such a sentence effectively removes the statutory right to remission and set-off under Section 428 of the Code of Criminal Procedure, and that only Constitutional Courts, exercising powers under Articles 136 and 142 or appellate jurisdiction, could impose such special category sentences as laid down in several Supreme Court judgments including Swamy Shraddananda (2) and recently reiterated in Kiran v. State of Karnataka (2025), therefore, the defence sought either acquittal or at least modification of sentence to ordinary life imprisonment, while on the other hand, the State, represented by the prosecution, strongly defended both the conviction and the severity of the punishment, arguing that the murder of a defenceless child after deliberate preparation constituted one of the gravest categories of crime warranting strict punishment, the prosecution pointed out that several witnesses including PW1 (mother), PW2, PW4, PW11 and PW15 consistently deposed about the accused’s hostile behaviour, theft, snatching of belongings of devotees, and repeated confrontations with the complainant, thereby clearly establishing motive, it was argued that preparation was proved through independent witnesses PW7 to PW9, who supported the prosecution version that the accused had purchased sleeping tablets shortly before the incident, and that the tablets were later recovered at the instance of the accused under a valid mahazar, the State also relied heavily on the recovery of the dead body at the instance of the accused, supported by PW3 and PW21, which constituted a strong incriminating circumstance under Section 27 of the Evidence Act, the prosecution further submitted that medical and forensic evidence corroborated homicidal death and linked blood samples and other materials recovered to the deceased, thereby completing the chain of circumstantial evidence, and on the issue of sentence, while acknowledging that the Supreme Court had clarified the limits of Sessions Court powers, the State argued that given the brutality of the crime, the High Court should itself consider imposing life imprisonment without remission if legally permissible, or at least ensure that the accused remains in prison for a substantial minimum period, thus urging the Court not to dilute the punishment merely on technical grounds of sentencing jurisdiction.

Judgment:

After a detailed examination of oral, documentary, and scientific evidence, the Karnataka High Court categorically held that the conviction of the accused under Section 302 IPC was fully justified and did not warrant interference, the Court noted that although the case was based on circumstantial evidence, the prosecution had successfully established every crucial link in the chain including motive, preparation, recovery, and medical corroboration, the Bench observed that evidence of PW1, PW2, PW4, PW11 and PW15 clearly demonstrated longstanding hostility of the accused towards the complainant and her family, which provided a strong motive for committing the offence, the Court further observed that preparation was proved through the purchase of sleeping tablets, supported by medical shop witnesses PW7 to PW9, and the recovery of remaining tablets at the instance of the accused further strengthened the prosecution case, the recovery of the dead body based on the voluntary disclosure statement of the accused, supported by PW3 and PW21, was treated as a highly incriminating circumstance, the Court also relied upon medical and forensic evidence, noting that the post-mortem confirmed homicidal death and the FSL report matched blood samples and other material, thereby scientifically corroborating the prosecution story, the Bench held that each circumstance was proved beyond reasonable doubt and all circumstances taken together formed a complete chain pointing exclusively to the guilt of the accused, thus leaving no scope for alternative hypotheses of innocence, and therefore, the conviction under Section 302 IPC was affirmed, however, on the question of sentence, the High Court found serious legal infirmity in the Sessions Court order directing that the accused shall undergo life imprisonment till his natural death, the Bench referred extensively to the Supreme Court’s ruling in Kiran v. State of Karnataka (2025), where it was clearly held that the power to impose life imprisonment without remission lies only with Constitutional Courts and not with Sessions Courts, particularly when such sentence is imposed as an alternative to the death penalty, the High Court observed that the Sessions Court had no authority to deny remission or to exclude the benefit of set-off under Section 428 CrPC by prescribing that the convict must remain in prison for the remainder of his natural life, the Court clarified that while life imprisonment in law ordinarily means imprisonment for the remainder of natural life, the power to expressly bar remission and statutory benefits is a special constitutional power that must be exercised only by the High Court or Supreme Court after due consideration, and not by a trial court, therefore, the Bench held that the sentence required modification, and accordingly converted the punishment from “life imprisonment till natural death” to simple “imprisonment for life”, thereby restoring the possibility of remission and statutory set-off as per law, while making it clear that such modification did not in any way reduce the seriousness of the offence or undermine the findings of guilt, the appeal was thus partly allowed only to the limited extent of modifying the sentence, while the conviction for murder was fully upheld, and the judgment stands as an important reaffirmation that sentencing discretion must operate strictly within constitutional and statutory limits, even in cases involving extremely heinous crimes.