Father Benedict vs State of Kerala - Case Analysis

Last Updated on May 19, 2025
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Case Overview

Case Title

Father Benedict vs State of Kerala

Case No.

Criminal Appeal no. 27 of 1966 & 356 of 1966

Jurisdiction

High Court of Kerala

Date of the Judgment

7th April 1967

Bench

Justice P.T. Raman Nair and Justice V.P. Gopalan Nambiyar

Petitioner

Father Benedict

Respondent

State of Kerala

Provisions Involved

Section 7, Section 8, Section 11, Section 25, Section 26 and Section 32(1) of the Indian Evidence Act, 1872

Introduction of Father Benedict vs State of Kerala

The case of Father Benedict vs State of Kerala revolves around the accusations against a 37-year-old Roman Catholic Priest who was charged with the abduction and murder of Mariyakutty. The circumstances leading to the crime including the background of both the deceased and the accused as well as the timeline of events and subsequent legal proceedings form the basis of this case. The reliance of the Prosecution on circumstantial evidence and the lack of direct evidence play an important role in the decision of the High Court.

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Historical Context and Facts of Father Benedict vs State of Kerala

The case at hand revolves around a 37-year-old Roman Catholic Priest, Father Benedict who was accused of abducting and murdering Mariyakutty, a 43-year-old woman. 

Background of the Deceased

Mariyakutty, the deceased was a widow living with her mother and five children in a town in Alleppey. She had been married thrice and five years before her death she left her last husband due to his paralysis. Her youngest son, Joy was born about two years prior to her death coinciding with the passing of her third husband.

Background of Accused

Father Benedict managed two different churches from April 1960 to May 1964 including Chakkara Kadavu Church and St. Joseph’s Orphanage in Changanacherry.

Timeline of events

On 15th June 1966 Mariyakutty left her home around 1:00 PM and did not return. She had mentioned to her mother about an invitation from Father Benedict to visit a bookstore on that date. The next day an unidentified body of a woman was discovered on the road leading from Mannamaruthi towards the forest with severe injuries including a cut throat and multiple wound

Discovery of the body

The landowner discovered the body and was mostly naked from the waist up and was found facing upwards. She had suffered severe injuries including a throat cut from ear to ear, numerous wounds on her chest and abdomen, and an injury covering the left side of her face. No clothes or jewellery were missing from the body, and a bed sheet covered the lower half with an umbrella found nearby.

Registration of FIR

A case was registered under Section 302 of the Indian Penal Code, 1860. The sub-inspector visited the crime scene and documented his observations.

Testimony of the Eye-Witness

On the night of the murder, a man living about 150 yards from the crime scene reported waking up to a cry of “My God! I’m being killed! My head is broken!” He shouted twice, asking, “Who is that?” but received no response. He then woke his wife to share what he heard and, assuming it was a quarrel between nearby neighbours, went back to sleep.

Decision of the Sessions Judge

The Sessions Judge convicted Father Benedict under Section 364 and Section 302 for the abduction and murder of Mariyakutty. The Court sentenced him to rigorous imprisonment for 5 years. 

Appeal in the High Court of Kerala

Aggrieved by the decision of the Sessions Judge, Father Benedict filed an appeal in the High Court of Kerala.

Issue addressed in Father Benedict vs State of Kerala

The main question which was addressed in this case-

  • Whether the prosecution could prove that the accused had sufficient motive to murder the deceased? 
  • Whether the witnesses and evidence presented are reliable?

Legal Provisions involved in Father Benedict vs State of Kerala

Section 7 of the Indian Evidence Act

Section 7 provides that facts which are the occasion, cause or effect, immediate or otherwise, of relevant facts, or facts in issue, or which constitute the state of things under which they happened, or which afforded an opportunity for their occurrence or transaction, are relevant.

Section 8 of the Indian Evidence Act

Section 8 states that any fact is relevant which shows or constitutes a motive or preparation for any fact in issue or relevant fact. The conduct of any party, or of any agent to any party, to any suit or proceeding, in reference to such suit or proceeding, or in reference to any fact in issue therein or relevant thereto, and the conduct of any person an offence against whom is the subject of any proceeding, is relevant, if such conduct influences or is influenced by any fact in issue or relevant fact, and whether it was previous or subsequent thereto.

Section 11 of the Indian Evidence Act

Section 11 provides that-

  1. if they are inconsistent with any fact in issue or relevant fact
  2. if by themselves or in connection with other facts they make the existence or non-existence of any fact in issue or relevant fact highly probable or improbable.

Section 25 of the Indian Evidence Act

Section 25 of the Act states that no confession made to a police officer shall be proved as against a person accused of any offence.

Section 26 of the Indian Evidence Act

Section 26 provides that no confession made by any person whilst he is in the custody of a police officer, unless it be made in the immediate presence of a Magistrate shall be proved as against such person.

Section 32(1) of the Indian Evidence Act

Section 32 of the Act provides that the statements, written or verbal, of relevant facts made by a person who is dead, or who cannot be found, or who has become incapable of giving evidence, or whose attendance cannot be procured without an amount of delay or expense which under the circumstances of the case appears to the Court unreasonable, are themselves relevant facts in the following cases-

  1. When it relates to the cause of death-
    When the statement is made by a person as to the cause of his death, or as to any of the circumstances of the transaction which resulted in his death, in cases in which the cause of that person’s death comes into question. Such statements are relevant whether the person who made them was or was not, at the time when they were made, under expectation of death, and whatever may be the nature of the proceeding in which the cause of his death comes into question.

Judgment and Impact of Father Benedict vs State of Kerala

The High Court of Kerala evaluated the circumstantial evidence presented by the prosecution. It ruled that the circumstantial evidence relied upon was not properly established. The Court noted that there were no eyewitnesses to the crime and the accused did not confess to committing the offence.

The High Court after analysing the facts and circumstances of the case concluded that the Prosecution had failed to meet the burden of proof necessary to secure a conviction. Thus, the Court acquitted Father Benedict of all charges and ordered his release. The decision in this case highlights the importance of substantial evidence in criminal proceedings and underlines the principle that an accused is presumed innocent until proven guilty.

Conclusion

The High Court of Kerala in Father Benedict vs State of Kerala determined that the prosecution failed to establish circumstantial evidence. The absence of eyewitnesses and the lack of a confession from the accused led the court to conclude that the prosecution did not meet the necessary burden of proof. Thus, the Court acquitted Father Benedict of all the charges.

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FAQs about Father Benedict vs State of Kerala

The main question which was addressed in this case was whether the prosecution could prove that the accused had sufficient motive to murder the deceased.

The key legal provisions involved in this case were Section 7, Section 8, Section 11, Section 25, Section 26 and Section 32(1) of the Indian Evidence Act, 1872.

The High Court acquitted Father Benedict of the charges due to lack of evidence.

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