Madurai Bench Upholds Life Sentence for Man Who Bludgeoned Engineering Student in Classroom Over Rejected Relationship

The Madurai Bench confirmed conviction under Section 302 IPC after holding that an injured professor's dock identification was reliable without a test identification parade, and that hostile student witnesses had been won over during a 25-month gap before cross-examination.

A Division Bench of the Madurai Bench of the Madras High Court, comprising Justice N. Anand Venkatesh and Justice K.K. Ramakrishnan, on 15 June 2026 dismissed the criminal appeal of Udayakumar, the sole accused convicted of murdering a third-year BE Civil Engineering student, Sonali, inside a classroom at Karur College of Engineering on 30 August 2016. The Additional District and Sessions Judge, Fast Track Mahila Court, Karur had convicted him in S.C. No.24 of 2017 on 1 February 2022, imposing life imprisonment under Section 302 IPC along with concurrent sentences for house trespass, causing hurt, obscene language, and criminal intimidation. The Division Bench found no reason to interfere, holding that the evidence of the injured professor who witnessed the attack was credible and sufficiently corroborated, and that the mass turning of student eyewitnesses hostile did not dislodge the prosecution's case.

The Attack in the Classroom

The prosecution's case, as recorded in the judgment, was that Sonali and Udayakumar had previously been in proximity. When she chose to distance herself, he became agitated. Udayakumar had studied in the same college in the same branch but had been debarred from examinations for lack of attendance and had discontinued his studies.

On 30 August 2016, at about 10.30 a.m., while PW1 — an Assistant Professor — was conducting class, Udayakumar trespassed into the classroom wearing the college uniform, abused Sonali in filthy language, and struck her repeatedly on the head with a wooden log (MO1). She fell unconscious. When PW1 intervened, the accused attacked him as well, causing an injury to his left wrist. Udayakumar then intimidated everyone present and fled.

PW1 lodged a written complaint (Ex.P1) with PW30, who registered FIR No.810 of 2016 at about 12.00 hrs. for offences under Sections 294(b), 324, 506(II) and 307 IPC. Sonali died at Apollo Hospital, Madurai, at about 15.02 hrs. the same day. The investigating officer filed an alteration report converting the offence to Section 302 IPC. A further alteration added Section 449 IPC.

The autopsy, conducted by PW24, recorded multiple sutured lacerated wounds on the right parietal and occipital regions, a comminuted fracture over both occipital regions, diffuse subdural and subarachnoid haemorrhage over both cerebral hemispheres, and fractures of the anterior and posterior cranial fossae. The final opinion was that the deceased died of cranio-cerebral injury.

The Challenge: Identity Without a Test Identification Parade

Senior counsel for Udayakumar pressed a single dominant argument: PW1 had joined the college only 45 days before the incident and did not know the accused beforehand. No test identification parade was conducted. PW1 identified the accused for the first time in the dock. That identification, the defence argued, was wholly unbelievable and the accused was entitled to the benefit of doubt.

The defence also pointed to discrepancies between PW1's complaint and his court testimony — specifically about the colour of the accused's dress and the manner in which the complaint was given — and challenged the recovery of MO1. Witnesses consistently said the wooden log was dropped in the classroom, whereas the investigating officer PW31 claimed it was recovered from a bush after the accused's arrest.

Several eyewitnesses among the students — PW3, PW4, PW5, and PW26 — turned hostile. PW27, another student who had identified the accused in chief examination on 25 April 2019, was recalled for cross-examination only on 24 September 2021 — a gap of nearly 25 months — and then stated that the accused was not present at the time of the incident.

How the Bench Reasoned

The Division Bench addressed the test identification parade argument directly. It held that a test identification parade is an aid to investigation, not a requirement of proof before a court. What matters in court is whether the dock identification is trustworthy and reliable. The absence of a parade does not automatically discredit a witness.

The Bench placed particular weight on PW1's status as an injured witness. He sustained injuries in the same transaction, caused by the same accused. The Bench drew on the Supreme Court's judgment in Pargan Singh v. State of Punjab and another, reported in 2014 (14) SCC 619, which examined the science of memory under extreme stress. That judgment held that when a person is attacked or witnesses a brutal assault, the brain captures the assailant's face in a manner that can persist for a lifetime. The Apex Court had upheld identification after 7½ years, in an incident lasting 90 seconds, without prior acquaintance and without a test identification parade.

Applying that reasoning, the Madurai Bench noted that the incident here occurred on 30 August 2016 and PW1 identified the accused in court on 15 October 2018 — a far shorter interval. PW1 had not merely observed the accused from a distance; he had been physically attacked by him in broad daylight. The Bench held that such an experience embeds the assailant's face in memory and that PW1's identification could not be doubted.

On the discrepancies in PW1's evidence, the Bench found them minor. The variations in the description of the accused's dress colour and the mechanics of lodging the complaint did not touch the core of the testimony. PW1 had gathered the accused's name from other students who knew him, since Udayakumar had studied in the same college and branch. That explanation was accepted.

The Bench dealt with PW27's hostile cross-examination by invoking two Madras High Court precedents — Dharmaraj v. The Inspector of Police, Athanakottai Police Station, reported in 2015 (2) LW (Crl.) 458, and Rasukannu @ Rengasamy and Karthik v. State through the Inspector of Police, Alangudi Police Station, reported in 2018 (1) MLJ 306 — which hold that where a witness is cross-examined after a long interval from chief examination, and circumstances suggest the witness may have been won over, the cross-examination evidence can be eschewed. The Bench found it “quite shocking” that PW27, who had specifically deposed about the accused's identity in chief, reversed course 25 months later. It held PW27 had been won over and discarded the cross-examination statement.

On the recovery of MO1, the Bench was candid about the investigating officer's failure. PW31 had, in the Bench's words, “goofed up the investigation in a case which was otherwise a open and shut case” by fabricating a recovery from a bush when the weapon was plainly left at the scene. PW15, a witness to the observation mahazar, had spoken to MO1 being present at the scene. PW24, the postmortem doctor, confirmed that the injuries were capable of being caused by MO1. The Bench held that the investigator's lapse did not discredit the prosecution's case on the weapon.

The Bench also applied common sense reasoning. The college had security arrangements that would not admit a total stranger during working hours. Udayakumar had been a student there, knew the layout, and entered wearing the college uniform. He went directly to the classroom where Sonali was present. No motive existed for any third party to commit the attack. The motive — a broken relationship — pointed squarely to the accused.

The Court's Observations on Student Witnesses

The Bench expressed strong disappointment at the conduct of the student eyewitnesses. It noted that no student attempted to stop the attack while it was happening, no student tried to overpower the accused after the incident, and those who had given statements under Section 164 Cr.P.C. chose to depose to the contrary in court.

The Bench observed that the students “had let down the deceased by not supporting the case of the prosecution.” It said that education had not built character in those students and that each hostile student had exhibited pusillanimity. The Bench warned that unless acts of this nature are identified and punished with the active cooperation of all concerned, such incidents will continue.

Outcome

The Division Bench dismissed Criminal Appeal (MD) No.301 of 2023 and confirmed the judgment and order dated 1 February 2022 passed in S.C. No.24 of 2017 by the Additional District and Sessions Judge, Fast Track Mahila Court, Karur. The sentences — life imprisonment under Section 302 IPC, ten years rigorous imprisonment under Section 449 IPC, two years under Section 324 IPC, two years under Section 506(II) IPC, and three months under Section 294(b) IPC, all running concurrently — stand confirmed. The trial court was directed to take steps to secure the presence of the accused to undergo the remaining period of sentence.