AP High Court Commutes Death Sentence in Double Murder Case, Acquits Mother-in-Law for Want of Overt Act

The Andhra Pradesh High Court modified death sentences against two accused in a double murder within weeks of marriage, finding no material to foreclose possibility of reformation and rehabilitation.

A Special Division Bench of the High Court of Andhra Pradesh at Amaravati, comprising Justice K. Suresh Reddy and Justice A. Hari Haranadha Sarma, on 1 July 2026 declined to confirm the death sentences awarded by the IV Additional District and Sessions Judge, Kurnool, against Accused Nos. 1 and 2 in Sessions Case No. 254 of 2023. The Bench commuted those sentences to rigorous imprisonment for life without any remission. Simultaneously, it acquitted Accused No. 3 — the mother of Accused No. 1 — of all charges after finding that no specific overt act had been attributed to her by any witness. The court disposed of a death reference and two criminal appeals by a single common judgment.

The Killings and the Sessions Court Verdict

The incident occurred on 14 March 2023, barely two weeks after the marriage between Accused No. 1 (Narapuram Shravan Kumar @ Shravan) and the first deceased (Kotha Rukmini, “D1”). The marriage had been solemnised on 1 March 2023 at Wanaparthy Town. After the wedding, a dispute arose because the marriage was not consummated during the three days the accused family stayed at the house of P.W.1, the father of D1.

On the morning of 14 March 2023, Accused No. 1 came to Wanaparthy and persuaded P.W.1, D1, and D2 (the mother of D1, Kotha Ramadevi) to accompany him to Kurnool for discussions. On arrival at the house of the accused at Chinthalamuni Nagar, Kallur Mandal, Accused No. 2 (Narapuram Varaprasad @ Prasad, father of Accused No. 1) directed P.W.1 and D2 to go to a room on the first floor, while Accused No. 1 took D1 to a room on the ground floor.

About 45 minutes later, P.W.1 and D2 heard D1 cry out. When they tried to descend, Accused No. 2 attacked and stabbed D2 indiscriminately with a knife; she died on the spot. P.W.1 was also stabbed by Accused No. 2 and sustained grievous injuries. P.W.1 managed to reach the ground floor, where he found D1 lying dead in a pool of blood. Accused No. 1 had stabbed D1 with a knife in their room. All three accused fled.

Neighbours P.Ws. 2 to 4 heard P.W.1's cries, rushed to the scene, and shifted him to Government General Hospital, Kurnool. The Inspector of Police, P.W.13, received information through Dial 100 at around 12:45 p.m. and registered Crime No. 62 of 2023 for offences under Sections 498-A, 302, and 307 read with 34 IPC. All three accused were arrested on 15 March 2023. Post-mortem examinations confirmed that both D1 and D2 died of haemorrhage and shock resulting from multiple stab injuries.

After trial, the learned Additional Sessions Judge convicted Accused Nos. 1 and 2 under Section 302 IPC and sentenced both to death. Accused No. 1 was also convicted under Section 302 IPC for the killing of D2 and under Section 307 read with 34 IPC, both carrying life imprisonment. Accused No. 2 was additionally convicted under Section 307 IPC with life imprisonment. Accused Nos. 2 and 3 were convicted under Section 302 read with 34 IPC with life imprisonment, and Accused No. 3 was convicted under Section 307 IPC with ten years' rigorous imprisonment. The trial court made a reference to the High Court under Section 366 of the Code of Criminal Procedure for confirmation of the death sentences, registered as Referred Trial No. 1 of 2024. Accused No. 3 filed Criminal Appeal No. 604 of 2024 against her conviction, and Accused Nos. 1 and 2 filed Criminal Appeal No. 608 of 2024 against the death sentences.

The Sole Eye-Witness and the Absence of an Overt Act Against Accused No. 3

P.W.1 was the only direct injured eye-witness to the occurrence. The Division Bench found his testimony “clear and cogent” in establishing that Accused Nos. 1 and 2 caused the deaths of D1 and D2 and inflicted injuries on P.W.1. P.Ws. 2 to 4 were not eye-witnesses; their evidence went only to the fact that they reached the scene after the event. P.Ws. 1 to 4 consistently deposed about the marriage date of 1 March 2023 and the incident date of 14 March 2023 — a span of two weeks.

The Bench drew a clear distinction regarding Accused No. 3 (Narapuram Krishnaveni, mother of Accused No. 1). P.W.1 had not attributed any overt act to her. His evidence placed her merely as present in the house at the time. On that basis, the court held that the prosecution had proved the guilt of Accused Nos. 1 and 2 beyond reasonable doubt for the deaths of D1 and D2 and the attempt on P.W.1, but that the conviction and sentences against Accused No. 3 were liable to be set aside entirely.

Why the Death Sentence Was Not Confirmed

The central question before the Division Bench was whether the facts brought the case within the “rarest of rare” threshold established in Bachan Singh v. State of Punjab, AIR 1980 SC 898. The court directed the District Collector, Kurnool, the Superintendent of Police, Kurnool, and the Superintendent, Central Prison, Rajamahendravaram, by order dated 22 December 2025, to submit reports on the accused in terms of the directions in Manoj and others v. State of Madhya Pradesh, (2023) 2 SCC 353.

The reports returned no adverse remarks. They disclosed that Accused No. 1 is a B.Tech graduate who had previously been employed at a call centre in Hyderabad. Accused No. 2 earned his livelihood selling idlis on the streets of Kurnool. The family belongs to the Below Poverty Line category and lives in a small house at Chinthalamuni Nagar. Neither Accused No. 1 nor Accused No. 2 had any prior criminal antecedents.

Relying on the framework in Bachan Singh, the Bench emphasised that the court must balance aggravating and mitigating circumstances relating to both the crime and the criminal. The mitigating factors identified in Bachan Singh include, among others, the probability that the accused would not commit further acts of violence and the probability of reformation and rehabilitation. The State is required to prove by evidence that the accused do not satisfy those conditions before the death penalty can be imposed.

The Bench also drew on the extended discussion in Manoj and others, where the Supreme Court traced the legislative shift from a position requiring written reasons for not imposing death, to the post-1973 framework under Section 354(3) of the Code making life imprisonment the norm and requiring “special reasons” for death. That judgment highlighted that the 262nd Law Commission Report found capital punishment sentencing had become judge-centric and called for genuine consideration of whether an offender is amenable to reform. The Supreme Court in Manoj had held that “implicit in this shift is the understanding that the criminal is not a product of only their own decisions.”

The Division Bench accepted that the offence was grave and heinous, resulting in the loss of two lives within a fortnight of a marriage. However, it found that the material on record did not establish that Accused Nos. 1 and 2 were beyond the possibility of reformation. There were no prior criminal antecedents, no evidence of a continuing threat to society, and no material to conclude that the alternative of life imprisonment was unquestionably foreclosed. On that analysis, the court held the case did not fall within the “rarest of rare” category.

Outcome

The Division Bench modified the death sentence imposed on Accused Nos. 1 and 2 for the offence under Section 302 IPC and sentenced them instead to rigorous imprisonment for life without any remission, along with a fine of Rs. 1,000 each, in default simple imprisonment for three months each. All other convictions and sentences against Accused Nos. 1 and 2 — including those for the remaining offences under Sections 302 and 307 IPC — were confirmed and left unaltered. All substantive sentences were directed to run concurrently.

Accused No. 3 (Narapuram Krishnaveni) was acquitted of all charges, and Criminal Appeal No. 604 of 2024 was allowed. The court directed that she be set at liberty forthwith if not required in any other case. Criminal Appeal No. 608 of 2024 was partly allowed to the extent of the modification in sentence, and the Reference in Referred Trial No. 1 of 2024 was answered accordingly. Pending miscellaneous applications, if any, were disposed of in consequence.