Renuka Prasad vs State Represented By Assistant Superintendent Of Police 2025 case gained attention for relying heavily on the testimony of the investigating officer, especially after key witnesses retracted their statements. The case raised important concerns regarding the role of Section 161 of Criminal Procedure Code and the evidentiary value of police investigations. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Renuka Prasad vs State Represented By Assistant Superintendent Of Police Introduction

Renuka Prasad vs State Represented By Assistant Superintendent Of Police 2025 is a landmark judgment which dealt with the murder of Ramkrishna, allegedly planned by his brother due to a property dispute. The case highlighted important legal issues around the admissibility of police-recorded statements when witnesses turn hostile.

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The case at hand centres around the brutal murder of Ramkrishna, who was killed in a premeditated attack allegedly planned by his own brother and associates due to a family property dispute. Despite numerous witnesses turning hostile during trial, the High Court convicted the accused based on circumstantial evidence and official testimonies. The following are the facts of Renuka Prasad vs State Represented By Assistant Superintendent Of Police -

Background and Motive

The deceased, Ramkrishna, was an employee at an educational institution founded by his father, who had divided his assets between his two sons, A1 and PW4. After the division of assets, Ramkrishna resigned from the institution managed by A1 and joined the institution run by PW4. This shift allegedly caused enmity between A1 and Ramkrishna, as Ramkrishna was seen supporting PW4 in the sibling rivalry.

Incident and Eyewitness Account

On the evening of 28th April, 2011, around 7:45 pm, Ramkrishna was brutally attacked and hacked to death in front of his young son, PW8, who witnessed the murder. PW8 immediately alerted relatives and the deceased was taken to the hospital but died at 8:40 pm the same day.

FIR and Investigation

PW8 filed the First Information Report which initiated the police investigation. The Prosecution alleged that A1, along with his employees A2 to A4, hired contract killers A5 and A6 through Advocate A7 to carry out the murder. The attack involved the use of weapons such as machetes and preparations like fake vehicle number plates were reportedly made to facilitate escape.

Trial and Witness Testimony

During the trial, 87 witnesses were examined to establish various aspects of the case including motive, conspiracy and offence itself. However, the vast majority of witnesses including important eyewitnesses and family members turned hostile by denying prior statements, refusing to identify assailants or disputing the alleged motive. Even PW8, the important eyewitness, failed to identify the accused or the weapons during trial.

Trial Court Verdict

On the basis of the above findings and due to the hostile stance of most witnesses, the Trial Court acquitted all the accused, except for A7. The Trial Court cited insufficient evidence to sustain a conviction.

High Court Judgment

The High Court reversed the acquittal and convicted A1 through A6 under Sections 302 and 120-B of the Indian Penal Code. The acquittal of A7 was upheld. The High Court relied mainly on the evidence of official witnesses such as investigating officers (IO) and recovered material, given the hostility of other witnesses. Aggrieved by this, an appeal was filed in the Supreme Court.

Renuka Prasad vs State Represented By Assistant Superintendent Of Police Legal Issues

The following issues were addressed in Renuka Prasad vs State Represented By Assistant Superintendent Of Police 2025 -

• Admissibility of Witness Statements Recorded under Section 161 Cr.P.C.
  The Court examined whether statements recorded by the police during investigation under Section 161 of Criminal Procedure Code can be relied upon as substantive evidence to prove the prosecution’s case in court.
• Reliability of Investigating Officer’s Testimony
  The Supreme Court in Renuka Prasad vs State Represented By Assistant Superintendent Of Police analysed to what extent the testimony of the investigating officer (IO) can be considered credible, especially when used to fill gaps in prosecution evidence or to prove the content of witness statements recorded under Section 161 of Criminal Procedure Code.

On 9th May, 2025, the 2-Judge Bench of the Supreme Court comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran in Renuka Prasad vs State Represented By Assistant Superintendent Of Police explained that while police officers can be considered reliable witnesses for recoveries of physical evidence such as weapons or narcotics based on voluntary disclosures by the accused, this credibility does not extend to their testimony regarding witness statements recorded under Section 161 of the Criminal Procedure Code (Now Section 180 of Bharatiya Nagarik Suraksha Sanhita, 2023).

The Supreme Court set aside the decision of the High Court which had overturned the acquittal of the accused by relying on the testimony of the Investigating Officer to prove witness statements recorded during investigation. It held that statements recorded under Section 161 Cr.P.C. do not have substantive evidentiary value and can only be used to contradict the witness during trial, not to substantiate the case of the Prosecution.

The decision in Renuka Prasad vs State Represented By Assistant Superintendent Of Police held that the Prosecution failed to establish motive, conspiracy or preparation for the offence beyond reasonable doubt since the witnesses turned hostile during trial and the investigating officer’s references to their Section 161 CrPC statements cannot be given legal sanctity. The Court distinguished previous rulings and affirmed that police testimony is reliable for physical recoveries under the Evidence Act but cannot replace direct evidence when witnesses turn hostile.

Accordingly, the Supreme Court in Renuka Prasad vs State Represented By Assistant Superintendent Of Police allowed the appeal, set aside the conviction and reinstated the acquittal. The case underscored that conviction cannot rest solely on the testimony of the Investigating Officer.

Conclusion

In Renuka Prasad vs State Represented By Assistant Superintendent Of Police 2025 the Supreme Court on 9th May, 2025 ruled that statements under Section 161 of Criminal Procedure Code cannot be used as substantive evidence and set aside the convictions. It highlighted the importance of direct and admissible evidence in securing convictions.