NAVAS @ MULANAVAS V. STATE OF KERALA

The Supreme Court’s decision in Navas @ Mulanavas v. State of Kerala examines the validity of convictions based exclusively on circumstantial evidence and the principles governing capital sentencing. In a case involving a brutal multiple homicide with no eyewitnesses, the Court reaffirmed the Sharad Birdhichand Sarda test and clarified the operation of Section 106 of the Indian Evidence Act. It also upheld the admissibility of forensic reports under Section 293 of the CrPC. While confirming the accused’s guilt, the Court rejected the death penalty, substituting it with 25 years’ rigorous imprisonment without remission, thereby strengthening the doctrine of proportional and humane sentencing.