Mariyadass v. State Rep.by

Madras HC19 Dec 2025CRL A/489/2023

Case brief

AI extract

What is this about?

Causation in criminal law; causa causans versus causa sine qua non; proximate and efficient cause; Section 304(II) IPC acquittal; electrocution death by wire tied on compound wall iron fencing; TNEB Wireman; Sushil Ansal v. State through CBI (2014) 6 SCC 173; Kurban Hussein Mohamedalli Rangawalla; Emperor v. Omkar Rampratap; credibility of eyewitness PW14; contradiction by neighbour witness PW24; benefit of doubt; Madras High Court; Sessions Judge Fast Track Mahila Court Krishnagiri; S.C.No.35 of 2021; Cr.No.407 of 2019 SIPCOT Police Station; appeal under Section 374(2) CrPC allowed; fine refunded.

What did the court decide?

Criminal Appeal allowed; conviction and sentence under Section 304(II) IPC in S.C.No.35 of 2021 set aside; appellant acquitted of the charge; fine amount, if any paid, to be refunded; bail bond, if any executed, stands discharged.

Mariyadass Vs State Rep.by — Murder and Culpable Homicide | Madras HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the victim sustained the electric shock due to the act of the appellant, i.e., whether it was the appellant who tied the electrical wire to the iron fencing above the compound wall. +1 more

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Court's answer

The TNEB report Ex.P3 only showed a single phase connection to PW24 and hypothetical responsibility had a wire been tied after connection; it did not suggest that the appellant had tied the wire in any particular manner and had caused the death.

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Ratio / Principle

The prosecution had established beyond reasonable doubt that the victim died due to electric shock.

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Key takeaways

PW9 (grandmother of the victim) admitted in cross-examination that she was not aware who actually tied the wire in the iron fencing; her evidence is of no avail to the prosecution.ratio¶¶60
Apart from the evidence of PW14 (husband of the victim), the prosecution examined no other witness to establish that the appellant tied the electrical wire; PW24, the best witness, was not examined during investigation and her testimony totally contradicted PW14; hence PW14's version is highly doubtful.ratio¶¶71
The doctrine of causa causans laid down in Sushil Ansal (2014) 6 SCC 173 is extendable to an offence under Section 304(II) IPC; even assuming the appellant tied the wire, the act was committed one year prior to the occurrence, and to attract Section 304(II) the prosecution had to show the act was the causa causans and not merely a causa sine qua non.

Detailed headnote1 paragraphs

Criminal Appeal (S.374(2) CrPC) against conviction under Section 304(II) IPC — Allowed (Sunder Mohan, J.). Victim died of electrocution on touching the compound wall of the neighbouring house; prosecution case was that the appellant, a TNEB Wireman, had tied the supply wire to the iron fencing above the shared compound wall about a year before the occurrence. Held: (i) apart from the testimony of the victim's husband (PW14), no witness established that the appellant tied the wire — PW24, in whose favour the wire ran and the best witness, was not examined during investigation and categorically denied any wire on the fencing; PW9 disclaimed knowledge of who tied it; the TNEB report Ex.P3 did not attribute the tying to the appellant; (ii) even assuming the appellant tied the wire, an act done one year prior could at most be a causa sine qua non and not the causa causans/proximate and efficient cause of death, the doctrine explained in Sushil Ansal v. State through CBI, (2014) 6 SCC 173 being extendable to Section 304(II) IPC. Conviction and sentence (ten years rigorous imprisonment and Rs.5,000 fine) set aside; accused acquitted; fine, if paid, to be refunded; bail bond discharged.

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Crl.A.No.489 of 2023

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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RESERVED ON : 12.12.2025

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PRONOUNCED ON : 19.12.2025

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CORAM :

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THE HON'BLE MR. JUSTICE SUNDER MOHAN

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Crl.A.No.489 of 2023

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Mariyadass … Appellant/Sole Accused

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The State of Tamil Nadu, Rep. by Inspector of Police, SIPCOT Police Station, Krishnagiri. [Cr.No.407 of 2019] ... Respondent/Complainant

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Criminal Appeal filed under Section 374(2) of Code of Criminal Procedure, against the conviction of the appellant/sole accused and sentence imposed on him in S.C.35 of 2021 dated 11.04.2023 on the file of the learned Sessions Judge, Fast Track Mahila Court, Krishnagiri and set aside the conviction and sentence and allow this appeal.

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For Appellant : Mr.AR. Karthik Lakshmanan

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For Respondent : Mr.S.Rajakumar Additional Public Prosecutor

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