A Kerala Sessions Court sentenced a woman to life imprisonment for murdering her one-and-a-half-year-old son by throwing him into the sea. The judgment highlights how circumstantial evidence, medical proof, and the “last seen” principle can firmly establish guilt beyond doubt.
KERALA: The Additional District and Sessions Court, Taliparamba, on January 22, sentenced Saranya Valsaraj to imprisonment for life for the kill of her one-and-a-half-year-old son, Viyan, an incident that took place in 2020 near Thayyil beach in Kannur district, Kerala.
The court held her guilty under Section 302 of the Indian Penal Code, concluding that the prosecution had successfully proved her guilt beyond reasonable doubt through a complete and unbroken chain of circumstances.
While delivering the judgment, the court clearly recorded its satisfaction with the evidence placed before it and observed:
“The prosecution has succeeded in proving the chain of circumstances that corroborates the guilt of the first accused in a complete and unbroken manner. Considering the integrity of the circumstances, this court is of the view that the prosecution has succeeded in proving the charge of murder against the first accused without any hollow of suspicion.”
At the same time, the court acquitted the co-accused, Nidhin P., who was alleged to have been her co-conspirator and abettor. The court found that there was no legally admissible evidence to show his involvement in the actual crime or any role in instigating or aiding the murder.
The judgment records:
“There is no case for the prosecution that he was involved in the actual commission of the crime. There is no evidence for the overt act of the second accused regarding the instigation, conspiracy or intentional aiding to commit the murder of the child. The evidence adduced by the prosecution regarding the conspiracy is not sufficient to array him as either a conspirator or an abettor in the act of homicide done by the first accused. Therefore, this court views that there is no overt act that has been proved against the second accused as alleged by the prosecution.”
The court also acquitted Saranya of the charges under Sections 109 and 120B IPC, relating to abetment and criminal conspiracy, and made important observations on how suspicion cannot replace proof.
It stated:
“The prosecution has failed to adduce cogent evidence to establish an agreement or meeting of minds between the accused to commit the murder of the child. The proof of an extramarital affair, the transfer of documents and the frequent calls between the lovers are wholly sufficient to attract the offence of criminal conspiracy. Even the material on records generates a suspicion that cannot substitute for legal proof. The prosecution’s case rests on suspicion arising from moral disapproval of the relationship rather than on legally admissible evidence.”
According to the prosecution, Saranya was living at her maternal home near Thayyil beach due to a strained marital relationship with her husband. On the night of the incident, she was sleeping in the house along with her husband, child, and other family members. In the early hours, she took the child from the bedroom on the pretext of breastfeeding him. It was alleged that she then took the child out of the house and threw him into the sea from the seawall, resulting in his death.
Later that morning, she informed her husband that the child was missing. Initially, a missing child case was registered. After the child’s body was found on the seawall, the case was converted into a murder investigation, and charges were framed under Sections 302, 120B, and 109 IPC.
The prosecution relied entirely on circumstantial evidence, including motive, last seen theory, scientific evidence, recovery of material objects, and medical findings. The defence challenged the case by pointing out the absence of direct evidence, alleged lapses in investigation, and contradictions in witness testimonies. The evidence of the child’s father was used to establish part of the chain of events, particularly the fact that the child was last seen with the mother.
Medical evidence played a crucial role in the case. The post-mortem revealed ante-mortem injuries on the child’s head, and the cause of death was found to be due to blunt injury. The forensic expert clarified that death was not due to drowning but due to the head injury caused by impact, consistent with the act of throwing the child onto a hard surface.
The scene of occurrence was established through bloodstains found on the granite stones of the seawall, supported by photographs and witness statements. Scientific examination also showed the presence of seawater elements on the clothes worn by Saranya, which remained unexplained by the defence.
The court examined the dog-tracking evidence produced by the prosecution but declined to rely on it as substantive evidence.
It observed:
“Because the evidence of a sniffer dog is not subject to cross-examination and cannot be treated as direct evidence, it is subject to the hearsay rule… A causa de cy, the investigating agency can use dog-tracking evidence to find a culprit and adduce evidence regarding the procedure. In the present scenario, the investigating agency located the first accused with the assistance of dog-tracking evidence, which can only be considered as an aid to the investigation.”
On the issue of motive, the court noted that the prosecution relied on writings in Saranya’s notebook indicating marital discord. While one entry was successfully proved to be in her handwriting, another line reading “I hate you…. Viyan Valsaraj” could not be legally attributed to her due to lack of proper handwriting verification, and therefore was not relied upon as proof of motive.
A key part of the judgment was the application of the “last seen” principle. The court observed that the child was last seen alive with his mother and was found dead shortly thereafter. It held that Saranya had special knowledge of what happened to the child and failed to provide any explanation.
The court remarked:
“It is a proven fact that the child was last seen together with his mother just a few hours before the death, and no other evidence for the appearance of the first accused or deceased elsewhere, which confirms the theory of the last seen together. The next morning, the child was found dead on the seawall. That being so, she had special knowledge regarding the disappearance of the child from her custody, and she failed to offer any explanations regarding the death of the child. Consequently, reasonable inferences can be drawn against the accused regarding the existence of the foundational facts.”
The court also strongly criticised parts of the investigation, especially attempts to introduce evidence relating to the accused’s “bad character”.
It noted:
“According to Section 54 of the Evidence Act, the previous bad character of the accused is not relevant except in reply. Therefore, the prosecution cannot adduce evidence regarding the bad character of the accused unless there is evidence of good character put forward by the accused. Unfortunately, the police investigation was conducted as moral policing, and some evidence has been adduced to prove the bad character of the first accused.”
Despite pointing out lapses in investigation and prosecution conduct, the court held that these deficiencies did not shake the core of the prosecution case against Saranya. The chain of circumstantial evidence remained intact and conclusive.
While deciding the sentence, the court carefully considered both aggravating and mitigating factors. It rejected the death penalty and explained its reasoning in clear terms:
“The quantum of the sentence is not intended to satisfy the thirst of society for sensationalism or media attention. It should be analyzed from the perspective of reformist theory… On that account, considering the younger age, low-income family background, absence of criminal antecedents and other socio-economic conditions of the accused, the balance sheet of the circumstances indicates a greater likelihood of reform.”
Accordingly, Saranya Valsaraj was sentenced to life imprisonment and fined Rs. 1 lakh. The court also ordered that the fine amount, if recovered, be paid to the child’s father as compensation under law.
Explanatory Table: Laws & Sections Applied in This Case
| Law / Section | Name of Provision | Why It Was Applied | Court’s Finding |
| Indian Penal Code, Section 302 | Punishment for Murder | Applied for the intentional killing of a one-and-a-half-year-old child | Proved beyond reasonable doubt against the first accused |
| Indian Penal Code, Section 120B | Criminal Conspiracy | Allegation of planning the murder along with co-accused | Not proved; mere suspicion and moral disapproval cannot replace legal proof |
| Indian Penal Code, Section 109 | Punishment for Abetment | Alleged instigation or aid by co-accused | Not proved due to absence of overt acts or direct involvement |
| Indian Evidence Act, Section 54 | Previous Bad Character | Prosecution attempted to show bad character of accused | Rejected; such evidence is irrelevant unless accused first leads good character evidence |
| Indian Evidence Act, Section 105 | Burden of Proof for Exceptions | Defence suggested mental illness | Rejected; burden was on accused, no plea or proof of insanity |
| Circumstantial Evidence Doctrine | Chain of Circumstances | Case based entirely on indirect evidence | Accepted; chain found complete and unbroken |
| Last Seen Theory | Presumption Based on Last Custody | Child last seen alive with mother | Applied; adverse inference drawn due to lack of explanation |
| Dog Tracking Evidence | Investigative Aid | Used during investigation | Not treated as substantive evidence; only an aid |
| Medical & Forensic Evidence | Cause of Death | To determine manner of death | Established death due to blunt head injury, not drowning |
Case Details
- Case Title: State v. Sharanya Valsaraj and Anr.
- Case Number: SC No. 508/2020
- Court / Bench: Additional District and Sessions Court, Taliparamba
- Presiding Judge: Sri. Prasanth K.N., Additional District and Sessions Judge
- Date of Judgment: 22 January 2025
- Accused:
- Saranya Valsaraj (First Accused)
- Nidhin P. (Second Accused)
- Charges Framed: Sections 302, 120B, and 109 of the Indian Penal Code
- Final Outcome:
- Saranya Valsaraj convicted under Section 302 IPC and sentenced to life imprisonment with a fine of Rs. 1,00,000
- Acquitted of charges under Sections 120B and 109 IPC
- Co-accused Nidhin P. acquitted of all charges
- Public Prosecutor: U. Ramesan
- Counsel for Accused:
- For Saranya Valsaraj: Manju Antony & Sebastian K. Jacob
- For Nidhin P.: R. Mahesh Varma & Vipin Surendran
Key Takeaways
- Courts do not convict on emotion or public outrage; only a complete and proven chain of evidence can sustain a murder conviction.
- Mere allegations of relationships or moral misconduct cannot be used to frame men or women without strict legal proof.
- The acquittal of the male co-accused shows that men cannot be punished simply for association or suspicion.
- Investigations driven by moral policing rather than evidence weaken cases and risk injustice to all parties, especially men.
- This case reinforces that true gender neutrality in law protects both innocent men and ensures accountability when guilt is proven.
This Could Change Your Case-Get FREE Legal Advice-Click Here!
Disclaimer: The views and opinions expressed in this article are those of the Indian courts and do not necessarily reflect the official policy or position of “ShoneeKapoor.com” or its affiliates. This article is intended for informational and educational purposes only. The content provided is not legal advice, and viewers should not act upon this information without seeking professional counsel. Viewer discretion is advised.